Jaghoori v. Holder, 772 F.3d 764 (4th Cir. Nov. 18, 2014) (stop-time rule for cancellation of removal does not apply retroactively against convictions where offense and guilty plea occurred before April 1, 1997, the effective date of the legislation by which Congress promulgated the rule in INA 240A(d)(1)(B), 8 U.S.C. 1229b(d)(1)(B), because considerations of fair notice, reasonable reliance, and settled expectations militate against retroactivity here, so the "traditional presumption" against retroactivity applies).

NOTE: Noncitizen in this case would have been eligible for cancellation on April 1, 1997, but for the stop-time rule. See Sinotes-Cruz v. Gonzales, 468 F.3d 1190, 1201 (9th Cir. 2006).