limitations of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (“IIRIRA”), we held that although the IJ conducted petitioners’ hearing in the absence of counsel, and although petitioners argued in a petition to us that they were not given an opportunity to present their case, 8 U.S.C. § 1252(d)(1) serves as a jurisdictional bar that “mandates exhaustion and therefore generally bars us, for lack of subject-matter jurisdiction, from reaching the merits of a legal claim not presented in administrative proceedings below.” Our sister circuits have likewise held that any alleged due process error correctable by the BIA is not reviewable on appeal if remedies were not exhausted in the agency’s tribunal. See, e.g., Bernal-Vallejo v. INS, 195 F.3d 56, 64 (1st Cir.1999) (<HOLDING>) (internal citation omitted); United States v.
holding that we will not review an issue or claim that was not presented to the bia in the petitioners notice of appeal or brief to the bia even if the bia considered the issue or claim sua sponte holding that the bia rule is reasonable holding that the bia could have addressed petitioners ineffective assistance of counsel claim and that while tjhere are some claims of denial of due process or deprivation of constitutional rights that are exempt from the exhaustion requirement because the bia has no power to address themthis case is not one of them recognizing a constitutional claim for ineffective assistance of counsel holding that the petitioners failure to raise his ineffective assistance of counsel claim before the bia deprived the district court of jurisdiction to hear the issue