(F)  AEDPA Limitation on INA § 212(c) Relief.  A noncitizen who has two or more convictions of crimes of moral turpitude, for each of which a sentence of one year or more was ordered by the court, is ineligible to apply for INA §   212(c) relief if s/he is in deportation proceedings begun prior to April 24, 1996 but before April 1, 1997.[281]  This situation is increasingly rare, however, because of the passage of time.

[281] INA § 212(c), as amended by the Antiterrorism and Effective Death Penalty Act of 1996, § 440(d), P.L. 104-132, 110 Stat. 279 (effective April 24, 1996).  If the proceedings had been commenced on or after April 24, 1996, however, the new AEDPA one-CMT sentence requirement of a potential sentence of one year or more for each of the two or more CMT convictions was sufficient to bar eligibililty for INA § 212(c) relief, since the new sentence requirement applies only to deportation or removal proceedings begun after the effective date of AEDPA.

SENTENCE - CONSECUTIVE SENTENCES
Oregon v. ICE, __ U.S. __, 129 S.Ct. 711 (Jan. 14, 2009) (Apprendi and Blakely, requiring jury to find sentencing factors that increase the maximum possible sentence do not apply to decisions whether to impose consecutive or concurrent sentences; the Sixth Amendment does not inhibit States from assigning to judges, rather than to juries, the finding of facts necessary to the imposition of consecutive, rather than concurrent, sentences).

Other

SENTENCE - SENTENCE IMPOSED - 12 MONTHS EQUALS ONE YEAR
12 months equals one year in immigration court. See Drakes v. Zimski, 240 F.3d 246, 251 (3d Cir. 2001); United States v. Christopher, 239 F.3d 1191, 1193 (11th Cir. 2001).