The Second Circuit extended the Supreme Court's decision in Vartelas v. Holder, and found that a lawful permanent resident who commits a crime before April 1, 1997, but who is not formally convicted of that crime until after April 1, 1997, is still not subject to grounds of inadmissibility for that conviction if he is returning from a brief, innocent, and casual trip abroad.

The full text of Centurion v. Sessions can be found here:

http://www.ca2.uscourts.gov/decisions/isysquery/b89fe7ff-0f51-4dd0-a70b-a7a14fd38a4f/11/doc/15-516_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/b89fe7ff-0f51-4dd0-a70b-a7a14fd38a4f/11/hilite/

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