The First Circuit remanded a case for the application of pre-1997 standards.  The Board of Immigration Appeals determined that an applicant in deportation proceedings had been convicted of a particularly serious crime.  Noting that the court had not yet determined whether pre-1997 law on particularly serious crimes would include non-aggravated felonies, the Court remanded the case for the agency to address this issue in the first instance.

The full text of Velerio-Ramirez v. Lynch can be found here: