Convictions previously waived can lead to removal

Kalbass v. Holder, No. 10-3527 (6th Cir. Nov. 29, 2011) (unpublished)

In this case, the alien received 212(c) relief in 1987.  He did not learn his lesson and accrued another conviction.  He was placed in removal proceedings and alleged to have committed multiple crimes involving moral turpitude.  The multiple crimes were one after the waiver and several before.  The court, following but not citing to BIA precedent, found that the waiver did not preclude future use of the offenses for immigration purposes.  The waiver waives the immigration consequences of the conviction but does not erase the conviction itself.