But in both Matter of West, 22 I. & N. Dec. 1405 (BIA 2000), and Matter of Kotliar, 24 I. & N. Dec. 124 (BIA 2007), the BIA held that the qualifying “release” for purposes of mandatory detention can include release from an arrest preceding a conviction for a removable offense. See Matter of West, 22 I. & N. Dec. at 1410 (recognizing that the term “release” has a broad range of meanings: “‘Release’ in this context can also refer to release from physical custody following arrest, as is the case with the respondent”); Matter of Kotliar, 24 I. & N. Dec. at 125 (“[W]e have held that an alien who is Case 1:15-cv-02724-RA Document 10 Filed 05/18/15 Page 21 of 30 18 released from criminal custody (including from an arrest preceding a conviction, as the respondent implicitly conceded took place here) . . . is subject to mandatory detention pursuant to [INA § 236(c)] . . . .”). The Third Circuit has followed the BIA’s reasonable interpretation.