event that occurs to, and not an action taken by, the defendant, considerations of fair notice, reasonable reliance and settled expectations are not particularly useful guides to whether the statutes retroactively affect the consequences of conviction. That fact in no way affects the Landgraf analysis. On several occasions, including in Land-graf itself, the Supreme Court reached the ultimate issue — whether new legal consequences attach to a past event — without the need to resort to these guiding principles. See, e.g., Landgraf, 511 U.S. at 282-84, 114 S.Ct. 1483 (noting fair notice considerations “muted,” but finding that increase in civil liability for past conduct was a retroactive effect); Rivers v. Roadway Express, Inc., 511 U.S. 298, 313, 114 S.Ct. 1510, 128 L.Ed.2d 274 (1994) (<HOLDING>); Hughes Aircraft Co. v. United States ex rel.
holding that a violation of the rules of professional conduct may not be used as evidence and citing terry cove north for the proposition that the sole remedy for a violation of the rules of professional conduct was the imposition of disciplinary measures holding that motion for a new trial whether for guilt or punishment requires a valid legal claim a court cannot grant a new trial unless the defendant shows that he is entitled to one under the law holding imposition of new legal liabilities for past conduct was retroactive holding that a city could not use past conduct to enjoin future protected speech holding iiriras denial of ability to apply for relief created a new disability and was impermissibly retroactive