Is a challenge to an immigration judge's order of removal wholly intertwined with the merits of the order?

8 U.S.C. 1252(a)(5) (emphasis added); see also Puri v. Gonzales, 464 F.3d 1038, 1041 (9th Cir. 2006) ("The REAL ID Act . . . eliminated district court habeas corpus jurisdiction over orders of removal and vested jurisdiction to review such orders exclusively in the courts of appeal.").

"Post-REAL ID Act cases considering the applicability of 1252 have distinguished between challenges to orders of removal and challenges that arise independently." Singh v. Gonzales, 499 F.3d 969, 978 (9th Cir. 2007). However, even when a challenge arises independently, the district court lacks jurisdiction over any challenge that "is wholly intertwined with the merits of [the] removal order." Singh v. Holder, 638 F.3d 1196, 1211 (9th Cir. 2011) (holding that the petitioner's habeas petition did nothing more than attack the immigration judge's removal order and was wholly intertwined with the merits of his removal order).