Velasco-Tijero v. Lynch, 796 F.3d 617 (6th Cir. Aug. 6, 2015) (non-LPR cancellation of removal criminal bars, under 8 U.S.C. 1229b(b)(1)(C), INA 240A(b)(1)(C), apply retroactively to noncitizens who were convicted prior to IIRAIRA, but placed into removal proceedings after IIRAIRA).

NOTE: This case found the noncitizen barred because his crime would have made him deportable under 8 U.S.C. 1227(a)(2)(A)(i), for a single CMT conviction punishable by at least one year in jail. The court did not address the issues decided in Matter of Cortez, 25 I&N Dec. 301 (BIA 2010) (noncitizen barred from cancellation if the offense falls under 8 U.S.C. 1227(a)(2)(A)(i), even if the offense qualifies for the petty offense exception to inadmissibility).