CA1: AEDPA and the INA

Santa-Cruz v. Gonzales, No. 05-2157, holds that that § 440(d) of AEDPA can be used to bar [former section] § 212(c) [of the INA] relief to an alien who engaged in criminal conduct prior to the effective date of AEDPA but who has been convicted by a guilty plea made after the effective date of AEDPA. Santa Cruz offers three cases in support of this argument.  The court holds that St. Cyr doesn’t help him because he knew about the AEDPA when he entered into the plea.  Indeed, most of his other arguments were dismissed just because AEDPA came into effect after the plea.