The Second Circuit determined that a person convicted of a pre-IIRIRA aggravated felony is not eligible for cancellation of removal for lawful permanent residents, and that a person who has been granted 212(c) relief cannot apply for cancellation of removal.  The Court further determined that the Supreme Court's decision in Vartelas v. Holder - which addressed the impermissible use of pre-IIRIRA crimes to classify a lawful permanent resident as an applicant for admission after a brief, innocent, and casual trip abroad - did nothing to change these rules.

The full text of Nunez Pena v. Lynch can be found here: