The Fifth Circuit has determined that it lacks subject matter jurisdiction to review the denial of an adjustment of status application for someone who has not been placed in removal proceedings, on the theory that the person may be able to renew the application at a future date if such proceedings commence.
The full text of Elldakli v. Garland can be found here:
https://www.ca5.uscourts.gov/opinions/pub/22/22-20344-CV0.pdf