Guzman v. Attorney General U.S., 770 F.3d 1077 (3d Cir. Nov. 3, 2014) (the stop-time rule, as enacted by the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Pub.L. No. 104"208, div. C., 110 Stat. 3009 (1996) (IIRIRA) (effective April 1, 1997), codified at INA 240A(d)(1), 8 U.S.C. 1229b(d)(1), is not impermissibly retroactive as applied to a 1995 criminal offense, where the commission and conviction pre-date the effective date of the stop-time rule, since the passage of IIRIRA did not change the legal consequences that faced petitioner as a result of his 1995 conviction; he was deportable in 1995 with no avenue for relief, just as he is deportable today, and the loss of an opportunity to delay deportation proceedings does not create a "new disability" under Landgraf v. USI Film Products, 511 U.S. 244, 114 S.Ct. 1483 (1994)).

Note: Unlike Sinotes-Cruz v. Gonzales, 468 F.3d 1190, 1201 (9th Cir. 2006), and Guzman v. Attorney General U.S., 770 F.3d 1077 (3d Cir. Nov. 3, 2014), the noncitizen in this case would not have been eligible for cancellation of removal on April 1, 1997, but for the stop-time rule