Immigration
When an attorney effectively withdraws from a case by nonappearance a year prior to disbarment, an agency does not abuse its discretion by denying review of evidence that might have been gathered between the effective withdrawal and the disqualification.
http://media.ca8.uscourts.gov/opndir/16/01/143684P.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.