Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Sixth Circuit: Alain Cuevas-Nuno v. William Barr
Alien's appeal citing an exceptional situation justifying sua sponte reopening of the matter did not sufficiently exhaust a claim for a statutory reopening of the matter due to exceptional circumstances.