The Eleventh Circuit has determined that the term “extreme cruelty,” as used in the VAWA cancellation of removal statutes, includes non-physical forms of abuse.
The full text of Ruiz v. Attorney General can be found here:
https://media.ca11.uscourts.gov/opinions/pub/files/202210445.pdf
An amended opinion can be found here:
https://media.ca11.uscourts.gov/opinions/pub/files/202210445.op2.pdf