In Lujan-Armendariz v. INS, 222 728 (9th Cir. 2000), the Ninth Circuit held that state rehabilitative relief from first-offense simple possession convictions was effective to eliminate all immigration consequences, by analogy to the Federal First Offender Act, 18 U.S.C. § 3607. While overruling Lujan prospectively, the Ninth Circuit continues to recognize state rehabilitative relief as erasing all immigration consequences of qualifying first controlled substances offenses, so long as the conviction occurred on or before July 14, 2011. (Nunez-Reyes v.