This week, a federal district court in Pennsylvania ruled that Temporary Protected Status (TPS) can serve as an admission for adjustment of status purposes, so long as the TPS beneficiary disclosed his or her prior unlawful entry on the TPS application. This decision accords with a developing trend in this area of the law. The Sixth Circuit, in Flores v. USCIS, previously came to the same conclusion, as did a district court in Washington in Ramirez v. Dougherty. The issue is currently pending before the Ninth Circuit.
This positive trend would be a terrific leap forward for TPS beneficiaries, many of whom have lived in the United States for more than a decade, and who are married to U.S. citizens. Decisions from courts of appeals (like the Flores decision) could allow these individuals to apply for their green cards from inside the United States, saving them the hardship of being separated from their family while they seek a green card abroad at a U.S. consulate.
The text of the Eastern District of Pennsylvania's decision in Medina v. Beers can be found here: http://www.legalactioncenter.org/sites/default/files/docs/lac/district%20court%20decision.pdf