Lovan v. Holder, 574 F.3d 990 (8th Cir. Jul. 31, 2009) (St. Cyr applies to respondents who were convicted following a trial, so respondent is eligible for relief under former INA 212(c)); following Atkinson v. Attorney General, 479 F.3d 222, 230 (3d Cir. 2007) (non-citizen need not show "actual reliance" to seek relief under former INA 212(c); but see Carranza-De Salinas v. Gonzales, 477 F.3d 200, 206-09 (5th Cir. 2007) (non-citizen convicted after trial must show actual reliance on the possibility of INA 212(c) relief to be eligible for that relief now); see also Wilson v. Gonzalez, 471 F.3d 111, 122 (2d Cir. 2006) (INA 212(c) relief exists for individuals convicted after a trial only if they show actual reliance on the possibility of relief); Restrepo v. McElroy, 369 F.3d 627, 631-40 (2d Cir. 2004) (same); Dias v. INS, 311 F.3d 456, 458 (1st Cir. 2002) (INA 212(c) relief is not available to individuals who were convicted after trial); Montenegro v. Ashcroft, 355 F.3d 1035, 1037 (7th Cir. 2004) (same); Armendariz-Montoya v. Sonchik, 291 F.3d 1116, 1121-22 (9th Cir. 2002) (same).