The Ninth Circuit has held that individuals who enter the United States as conditional residents (i.e., those who obtain their conditional residency through consular processing and not adjustment of status) are subject to the aggravated felony bar in section 212(h) of the INA.  In other words, such individuals are not eligible for a 212(h) waiver of inadmissibility if they have been convicted of an aggravated felony since their admission to the United States as conditional residents.

The full text of Eleni v. Sessions can be found here: