An applicant for special rule cancellation of removal must prove that he is not inadmissible for certain criminal offenses. In a decision earlier this week, the Ninth Circuit grappled with the situation of an applicant for special rule cancellation who had been convicted of crimes involving moral turpitude. The applicant argued that he could qualify for special rule cancellation in conjunction with a 212(h) waiver, which is used to wave the immigration consequences of certain types of convictions, including convictions for crimes involving moral turpitude. Deferring to the Board of Immigration Appeals' decision in Matter of Y-N-P-, the court determined that an applicant could for special rule cancellation could not rely on a 212(h) waiver to establish his statutory eligibility for cancellation.
The full text of Garcia-Mendez v. Lynch can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2015/06/08/12-73430.pdf