Enriquez-Gutierrez v. Holder, 612 F.3d 400 (5th Cir. Jul. 16, 2010) (a waiver under INA 212(c) may be used to waive a post-IIRAIRA conviction if the proceedings in which the waiver is sought began prior to April 1, 1997), agreeing with Garcia-Padron v. Holder, 558 F.3d 196 (2d Cir.2009).
jurisdiction:
Fifth Circuit