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: http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2015/D05-11/C:14-1866:J:Manion:aut:T:fnOp:N:1549550:S:0