Last month the BIA held that a waiver under INA § 212(h) cannot overcome ineligibility for cancellation of removal as a result of having been convicted of an offense under INA § 212(a)(2). Matter of Bustamante, 25 I&N Dec. 564 (BIA 2011) (Pauley, Wendtland, and Greer, Board Members). Board Member Wendtland wrote the panel’s decision.