If I knew how to put a black box around a posting to signify a sad, dark day for non-citizens, I would do it for this posting as I write about a new decision, Nunez Reyes v. Holder, which overrules Lujan-Armendariz v. INS,  a decision that recognized state expungements of simple possession drug offenses so that the harsh immigration consequences of drug convictions would not apply to those with expungements. First, what are the “harsh consequences” of simple possession offenses?…