stated that exhaustion of issues, as opposed to categories of relief, is a mandatory, as opposed to jurisdictional, requirement. See Lin Zhong v. U.S. Dep’t of Justice, 480 F.3d 104, 119-20 (2d Cir.2007). Nevertheless, we decline to exercise any authority to review this unexhausted issue in this case given that we believe it concerns a factual determination that should have been made by the agency in the first instance. We further note that Melnitsenko has not provided any evidence that Fourth Amendment violations such as the ones she alleges she experienced are widespread. 7 . This conclusion is also supported by our case law relating to whether border searches are "routine” for purposes of Fourth Amendment analysis. See, e.g., Tabbaa v. Chertoff, 509 F.3d 89, 97-101 (2d Cir.2007) (<HOLDING>); United States v. Irving, 452 F.3d 110, 123
holding that a plaintiff stated a fourth amendment claim where consecutive bodycavity searches were unnecessary holding that fourth amendment applicable in administrative searches for safety inspections holding that border searches where returning attendees of an islamic conference in canada were detained for four to six hours interrogated patted down fingerprinted and photographed were routine for fourth amendment purposes holding that consensual suspicionless searches of government employees personal belongings in the workplace were searches even though refusal to consent carried no criminal penalty and the searches were not for law enforcement purposes holding that taking an individual who was not suspected of any crime to a police station and into an interview room and detaining her for approximately four hours where it was made clear she was not free to leave violated the fourth amendment