The Eighth Circuit has declined to recognize any exception to the general rule that the denial of a sua sponte motion to reopen is non-reviewable. Although the court recognizes that three other circuits permits review of these decision if the agency relied on an incorrect legal premise, the court declined to adopt that rationale.
The full text of Vue v. Barr can be found here:
https://ecf.ca8.uscourts.gov/opndir/20/03/182595P.pdf