Good news for TPS and adjustment of status

Here's the scenario:

A person has temporary protected status (TPS).  However, before getting that status, he accrued more than one year of unlawful presence in the U.S.  With TPS, he can travel internationally if he applies and received advance parole.  However, if he leaves the country, he will trigger the 10-year-bar.  This bar is triggered when someone accrues more than one year of unlawful presence and then leaves the country.  He is allowed to return with the advance parole.

Let's say this person has an immediate relative.  He is in the United States legally so he should be able to adjust.  However, if he traveled, he now has a 10-year-bar.  If he didn't travel, he still can't adjust because he's inadmissible for entering without inspection when he initially came to the U.S.

Generally, a person who had returned on advance parole could apply for adjust status as an immediate relative only if he received a waiver for the 10-year-bar.  Is this still necessary?

Maybe not!  The Board of Immigration Appeals recently released a case, Matter of Arrabally, which establishes that leaving the country on advance parole does not trigger the 10-year-bar.  This could mean that a person can now adjust without needing a hardship waiver.

We'll have to see if this actually works.