Thom v. Ashcroft, 369 F.3d 158 (2d Cir. May 27, 2004) (conviction resulting from jury trial precludes eligibility for 212(c) relief from deportation; issuance of detainer notice did not begin proceedings so as to preclude application of later law; and laches did not bar deportation).
http://caselaw.lp.findlaw.com/data2/circs/2nd/012404p.pdf