Jerez-Sanchez v. Holder

Issue: (1) Whether Section 304(b) of the Illegal Immigration Reform and Immigrant Responsibility Act is inapplicable to pre-enactment convictions of all immigrants whose convictions predate IIRIRA’s enactment, or whether the section’s retroactivity instead (a) turns on an immigrant’s subjective reliance; (b) turns on objectively reasonable reliance; or (c) is categorically inapplicable to convictions obtained at trial; and (2) whether the presumption against retroactivity applies only when individuals can establish either subjective or objective reliance on prior law.