The Ninth Circuit has determined that a lawful permanent resident who seeks reopening of his proceedings more than 90 days after the issuance of a final order of removal based on post-conviction relief must show that he was diligent in seeking that relief, such that the 90-day motion to reopen deadline should be tolled.
The full text of Perez-Camacho v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2022/08/01/19-72063.pdf
An amended opinion can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2022/12/02/19-72063.pdf