" The refusal to sanction IIRIRA retroactivity in Vartelas v. Holder provides the kind of predictability that
LPRs need and deserve before they leave the USA and seek to return.
This, after all, is why retroactivity is disfavored .This is precisely...
though the Vartelas Court did not
have to decide if Fleuti still lived,
it reminds us that, despite the failure of the BIA to realize it in Collado-Munoz , Fleuti is at heart a constitutional decision. Vartelas belongs in this same line of cases...