The 9th Circuit Court of Appeals recently held that a Temporary Protected Status (TPS) recipient is eligible to apply for adjustment of status in the United States to become a lawful resident. The Court held that a TPS recipient is in lawful status as a nonimmigrant, and therefore has satisfied the requirements for adjustment of status, including inspection and admission. In Ramirez, et al. v. Brown, et al., 3/31/17, the TPS recipient originally entered the U.S. without inspection before he was granted TPS status. Subsequently, he married a U.S. citizen and applied for adjustment based on the visa petition filed by his wife.