The First Circuit has determined that the IMMACT amendments to section 212(c), which barred a person convicted of an aggravated felony who served five years or more in prison from seeking a 212(c) waiver, applied to a person whose criminal conduct pre-dated IMMACT but whose conviction post-dated IMMACT.

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

http://media.ca1.uscourts.gov/pdf.opinions/15-1864P-01A.pdf

Comment