In an unpublished decision, the Eleventh Circuit has held that the Board of Immigration Appeals cannot deny a motion to reopen for the purpose of applying for asylum and withholding of removal solely because the petitioner has been physically deported from the United States.
The full text of Linton v. Attorney General can be found here:
http://media.ca11.uscourts.gov/opinions/unpub/files/201513378.pdf