The Board of Immigration Appeals has determined that the exception to removability under section 212(a)(6)(A)(i) of the INA (present without admission or parole) applies only to a VAWA self petitioner.  It does not apply to a respondent who has been subjected to extreme cruelty, but who has not applied for benefits as a VAWA self petitioner.  The instant case involved a respondent who fled domestic violence in Guatemala at the hands of family members.  

The full text of Matter of Pangan-Sis can be found here: