Immigration.
Expedited removal procedures allow aliens no opportunity to raise matters of law related to their deportation - Circuit split flagged.
Checkbox on a form indicating that documents are attached is an insufficient avenue to raise matters not addressed in the other checkbox options.
As Congress implicitly incorporated the common law definition of the crime, a conviction on a state charge of Conspiracy that doesn't require the overt act in furtherance usually required in the modern law still qualifies.
http://www.ca4.uscourts.gov/Opinions/Published/142013.P.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.