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: http://www.ca2.uscourts.gov/decisions/isysquery/459cb87e-536e-4726-899c-3cfda9e87047/3/doc/15-27-ag_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/459cb87e-536e-4726-899c-3cfda9e87047/3/hilite/