good morning your honour's my name is nancy miller and i represent mary i guess you know in this case the main issue in the case is is whether or not section three twenty retroactively is a very serious very serious thing to impose upon anyone particularly upon aliens because they are so defenseless they vote they don't have the right to vote there is no one to speak for them and so congress doesn't get their attention congress does get the attention of those who don't like aliens and so if they think that it's a popular thing to do with they are as blind raf's head if they are bending to political pressure against unpopular groups they are likely to impose and  the right to do that but it's not an unlimited right and that they did so here explicitly with regard to three twenty one yes they did so are so under the elbow and under air are gone i mean  what would you have to argue that this was in permissible retroactive legislation or i think we need to look at united states versus i think we need to look at the   or at least it wasn't in the amended decision but i think that it makes sense and i think that it's that it should be looked at very carefully and going back to the other acquirement  ast for forty d and for now we're saying that you have no relief valuable at all it is rather stickley changing the expectations of people who had entered into pleas at any point in the past five ten fifteen twenty thirty thirty years ago who thought that they were settled and who aren't anymore and who have no way of making a plea bargain if they think that at some point the  change and he was suddenly going to be considered not think of talent and deal that he would work on who's going to be worthless which were down by well i still don't know whether it's right wrong or indifferent can look then it's since i since i don't think that the last committee and i specifically dealt with the issue of three twenty one i don't think that the fact that this court feels bound by the last come again on means that they cannot look to whether or they made a mistake you think or what i said i think that they were actually acting i think that they were going to perfectly pressure on i think that it was a popular thing to do and i think that's why i don't think that is constitutionally based i don't think that it's rational but i think that's why they get it and that's why i think it's wrong and others of us my time for th that the district court improperly deny petitioners hey b s it's clear this case is on all fours with united states versus alaska go medina and as a matter of fact the petitioner committed a crime prior to the effective date of the a death he was convicted he pled guilty of a crime prior to after the passage of adap up but prior to the effective day of a rear in that instance this court held that the petitioner did not hold a vested right to two t the time the petitioner pled guilty to a crime so she knew that that law would be a factor in the imminent future and that she would probably be deportable and eligible for two twelve three really the issue of expectations this case has been going on for over sixty six years at no point in this litigation has petitioned or ever explained to anyone what her expectations were that would entitle her final order of removal was entered she did not have an american husband and she did not have two american children she did have one child that's right  as expectations for what the law was at the time that she entered the plea that she wasn't around that she wasn't a portable because the offense that she was entering the plea to was entered more than five years after she had become a green card holder and since that's what someone is entitled to do under the law as it exists and that's why retroactivity is so dangerous and why it must be looked at so carefully and in this instance who writes changed