The Board of Immigration Appeals has determined that an applicant for VAWA cancellation of removal must prove that their abusive relative was a U.S. citizen or lawful permanent resident at the time of the abuse. In addition, if the abuser is the applicant’s spouse, the abuse must have taken place during the marriage.
The full text of Matter of L-L-P- can be found here: https://www.justice.gov/eoir/page/file/1370261/download