The Ninth Circuit has determined that the reinstatement of a removal order acts as a permanent bar to reopening that order. The court, however, recognized that the reinstatement bar does not affect a petitioner’s ability to rescind an in absentia order based on lack of notice. “Forfeiture of the right to reopen under § 1229a(c)(7) is part of the less favorable legal regime to which Padilla is now subject by unlawfully reentering and remaining in the United States despite his prior removal order.”
The full text of Padilla Cuenca v. Barr can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/11/13/16-72378.pdf