The Fourth Circuit has clarified that a motion to reopen to seek a marriage-based adjustment of status “does not require that the petitioner establish by clear and convincing evidence that his marriage was in fact bona fide; it requires only that the respondent establish a ‘strong likelihood’ that he would be able to demonstrate that his marriage was bona fide should the BIA grant his motion to reopen.”
The full text of Hussen v. Bondi can be found here: https://www.ca4.uscourts.gov/opinions/231047.P.pdf