In a relatively brief opinion, the Seventh Circuit deferred to the Board of Immigration Appeals' decision in Matter of Rivas, which determined that a lawful permanent resident charged with deportability grounds cannot seek a stand-alone 212(h) waiver, but must apply for the waiver in conjunction with an adjustment of status application.  The Seventh Circuit also affirmed an IJ's determination that a collateral attack on a criminal conviction is not necessarily good cause for a continuance.

The full text of Palma-Martinez v. Lynch can be found here: