Negrete-Ramirez v. Holder, 741 F.3d 1047 (9th Cir. Jan. 21, 2014) (the aggravated felony bar to a waiver of inadmissibility under INA 212(h) for a noncitizen previously admitted to the US as a LPR does not apply to someone who adjusted status without leaving the United States: only non-citizens who entered the United States as lawful permanent residents are barred from eligibility to apply for waiver).