(A)  Inadmissibility and Deportability.  Lawful permanent residents convicted of drug offenses can apply for cancellation of removal to avoid inadmissibility or deportability as long as the conviction is not an aggravated felony.[120]  If a lawful permanent resident was convicted prior to April 24, 1996, s/he may be able to obtain relief through a former INA § 212(c) waiver, even if the offense is an aggravated felony.[121] 

[120] See § § 24.3-24.6, infra.

[121] See § 24.28, infra.

BIA

CONTROLLED SUBSTANCES - RELIEF - PAULUS DEFENSE INAPPLICABLE
Matter of Martinez-Espinoza, 25 I. & N. Dec. 118 (BIA Nov. 4, 2009) (unidentified substance defense under Ruiz-Vidal v. Gonzales, 473 F.3d 1072 (9th Cir. 2007); Matter of Paulus, 11 I&N Dec. 274 (BIA 1965), inapplicable where burden is on noncitizen to show not ineligible for relief by a preponderance of the evidence). NOTE: This may not be true in the Ninth Circuit. See Sandoval-Lua v. Gonzales, 499 F.3d 1121, 1124 (9th Cir. 2007).