§ 212(c) relief was available to an LPR even if he had been convicted of an aggravated felony, as long as he did not serve a term of imprisonment of at least five years. Id. Ultimately, § 212(c) was repealed by the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) in favor of the new cancellation of removal provision (which categorically bars relief to aliens convicted of any aggravated felony). See IIRIRA, P.L. 104-208, § 304, 110 Stat. 3009 (1996).
In INS v. St. Cyr, the Supreme Court ruled that § 212(c) relief remained available to aliens whose criminal convictions resulted from plea agreements and who would have been eligible for § 212(c) relief at the time of their plea. 533 U.S. 289, 326 (2001). Therefore, although § 212(c) relief has been superseded by statute, there is a small (and decreasing) category of aliens who may still be eligible for such relief.