The Board of Immigration Appeals (BIA) has determined that in the Fifth and Ninth Circuits, a wave through admission qualifies as "an admission in any status" for the purposes of cancellation of removal for lawful permanent residents.  However, outside the Fifth and Ninth Circuits, applicants will need prove that they were admitted in a lawful status to meet the eligibility criteria for cancellation.  

The full text of Matter of Castillo Angulo can be found here:

https://www.justice.gov/file/1029381/download

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