context: It would distort the plain meaning of this language to limit the application of the SS 1105a(a)(3) bar to convictions for aggravated felonies following the enactment of the ADAA. Further, it is well settled that Congress has the authority to make past criminal activity a new ground for deportation.
citation_a.signal: see
citation_a.identifier: 353 U.S. 685, 690
citation_a.parenthetical: alien convicted of crimes involving moral turpitude in 1936 found deportable under Immigration and Nationality Act of 1952
citation_a.sentence: See id. at 32, citing Lehman v. United States ex rel. Carson, 353 U.S. 685, 690, 77 S.Ct. 1022, 1024, 1 L.Ed.2d 1122 (1957) (alien convicted of crimes involving moral turpitude in 1936 found deportable under Immigration and Nationality Act of 1952); Mulcahey v. Catalanotte, 353 U.S. 692, 694, 77 S.Ct. 1025, 1027, 1 L.Ed.2d 1127 (1957) (alien with 1923 narcotics convictions found deportable under 1952 Act); cf. Harisiades v. Shaughnessy, 342 U.S. 580, 593-96, 72 S.Ct. 512, 520-22, 96 L.Ed. 586 (1952) (upholding retroactive application of 1940 statute that made deportable aliens who had joined the communist party at any time after entering the United States).
citation_b.signal: cf.
citation_b.identifier: 342 U.S. 580, 593-96
citation_b.parenthetical: upholding retroactive application of 1940 statute that made deportable aliens who had joined the communist party at any time after entering the United States
citation_b.sentence: See id. at 32, citing Lehman v. United States ex rel. Carson, 353 U.S. 685, 690, 77 S.Ct. 1022, 1024, 1 L.Ed.2d 1122 (1957) (alien convicted of crimes involving moral turpitude in 1936 found deportable under Immigration and Nationality Act of 1952); Mulcahey v. Catalanotte, 353 U.S. 692, 694, 77 S.Ct. 1025, 1027, 1 L.Ed.2d 1127 (1957) (alien with 1923 narcotics convictions found deportable under 1952 Act); cf. Harisiades v. Shaughnessy, 342 U.S. 580, 593-96, 72 S.Ct. 512, 520-22, 96 L.Ed. 586 (1952) (upholding retroactive application of 1940 statute that made deportable aliens who had joined the communist party at any time after entering the United States).