The Fourth Circuit has denied a petition for review filed by a Salvadoran woman seeking cancellation of removal, holding that her 1994 reentry as a beneficiary of Deferred Enforced Departure did not count as an admission "in any status" for purposes of the seven-year continuous residence requirement under 8 U.S.C. § 1229b(a)(2), even though the immigration officer stamped her passport "Admitted."
The Court held that "status" in the INA is a term of art denoting membership in a congressionally defined immigration classification, and that DED, a purely discretionary act of executive forbearance, creates no such classification. Splitting from the Fifth and Ninth Circuits, the majority reasoned that "any status" broadens the range of qualifying statuses but does not dispense with the requirement that some status exist at all, and that her earlier Temporary Protected Status had already expired by the time of her 1994 reentry.
The full text of Montesinos Cisneros v. Blanche can be found here: https://www.ca4.uscourts.gov/opinions/231090.P.pdf