Lawful Domicile under Section 212(c) of the Immigration and Nationality Act

of the Court of Appeals for the Second Circuit has noted "the striking resemblance between . ..King Minos's labyrinth in ancient Crete... and the Immigration and Nationality Act" 1 and has felt it necessary to summon up "Thesean courage" to interpret certain of its provisions. 2 Such complexity has often produced disagreements among the circuits concerning the proper interpretation of various sections of the Act. 8 The most recent of these disagreements concerns section 212(c), which establishes eligibility requirements for discretionary waiver by the Attorney General 5 of statutory inadmissibility of 8 U.