An applicant is ineligible for VAWA cancellation of removal for non-lawful permanent residents if he is inadmissible for commission of two crimes involving moral turpitude. The Eleventh Circuit has determined that a petitioner cannot use a 212(h) waiver to waive this ground of inadmissibility in order to make himself eligible for VAWA cancellation. In so doing, the court deferred to the Board of Immigration Appeals' decision in Matter of Y-N-P-.
The full text of Arevalo v. US Attorney General can be found here:
http://media.ca11.uscourts.gov/opinions/pub/files/201611458.pdf