United States Third Circuit

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Guzman v. Attorney General United States, 13-3196

Petition for review of an order of removal by the Board of Immigration Appeals (BIA) on grounds that the so-called "stop-time rule," as enacted by the 1996 Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), was not impermissibly retroactive as applied to petitioner’s 1995 criminal offense, is denied, where: 1) the passage of IIRIRA did not change the legal consequences that faced petitioner as a result of his 1995 and 2005 convictions; 2) petitioner was deportable in 1995 with no avenue for relief, just as he is deportable today; and 3) the loss of opportunity to delay deportation proceedings does not create a "new disability" under Landgraf v. USI Film Products.

Appellate Information

  • Decided 11/03/2014
  • Published 11/03/2014


  • Rendell


  • United States Third Circuit


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