Sixth Circuit Decision on INA 121i
The Sixth Circuit held that 1996 Amendments To 212i Waiver Does Not Have Retroactive Effect. In Patel v. Gonzales, No. 04-3829 (6th Cir. Dec. 30, 2005), the court, joining the 4th and 9th Circuits, said that the 1996 elimination of the the 212(i) waiver for parents of US citizens, did not have a retroactive effect. http://www.ilw.com/immigdaily/cases/2006,0106-Patel.pdf
KJ