In a decision released last week, the Board of Immigration Appeals held that eligibility for relief under former § 212(c) of the INA depends on the date that the non-citizen entered a plea in the criminal proceeding not the date that the criminal court actually issued a sentence. Matter of Moreno-Escobosa, 25 I&N Dec. 114, 116 (BIA 2009).Section 212(c) was eliminated in 1996. However, under INS v. St. Cyr, non-citizens remain eligible for relief under former § 212(c) if they were convicted through a plea agreement and would have been eligible for relief at the time of their plea.