Sena v. Gonzales, 428 F.3d 50 (1st Cir. Nov. 2, 2005) (no due process violation through retroactive application of IIRAIRA expanded definition of "aggravated felony" to one who, at time he pled guilty to encouraging an alien to reside illegally in the United States, could not have been deported for that offense because it did not qualify as "aggravated felony").
jurisdiction:
First Circuit