In a shocking decision, the 9^th Circuit Court of Appeals held in Carrillo de Palacios v. Holder that pre-April 1, 1997 unlawful presence will retroactively count to erect the ten year bar to admissibility under Section 212(a)(9)(C)(i)(I). This bar applies to those who have been unlawfully present in the United States for an aggregate of one or who are removed and attempt to re-enter or re-enter unlawfully.  This reversal of precedent also foreshadows a claim that minor children can accumulate unlawful presence under this harsh section of law.