An Immigration Judge denied Sonia Tillery's application for VAWA cancellation of removal, suggesting that she had not proven that her marriage to her abusive US citizen was bona fide. The Board of Immigration Appeals affirmed. The First Circuit reversed, noting that the VAWA cancellation statute (unlike the VAWA self-petition statute) does not specifically require proof of a good faith marriage. While the statute does not permit an applicant to be inadmissible under the statutory provision related to marriage fraud, the Court noted that there was not an explicit finding of marriage fraud, and as such, remanded the case to the agency for further proceedings consistent with the opinion.
The full text of Tillery v. Lynch can be found here: http://media.ca1.uscourts.gov/pdf.opinions/14-1193P-01A.pdf