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: http://media.ca1.uscourts.gov/pdf.opinions/14-2318P-01A.pdf