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The Violence Against Women Act (VAWA), originally passed in 1994, was the first federal legislation acknowledging domestic violence as a crime. As part of this Act, Congress enacted 8 U.S.C. § 1229b(b)(2), a rule that allows battered spouses (or children) who are not citizens or nationals of the United States of America to seek the discretionary cancellation of the government’s removal of them from the country. The VAWA special-rule was enacted as a way to enable abuse victims to obtain discretionary deportation relief, allowing them to leave their abusers without fear of deportation or other immigration-related consequences. ...

The United States Court of Appeals for the Eleventh Circuit explored this issue in Ruiz v. United States Attorney General, where the court was tasked with determining whether the term “extreme cruelty,” within 8 U.S.C. § 1229b(b)(2)—titled “Special rule for battered spouse or child”—should be read to encompass both physical and mental abuse, or just physical abuse. In holding that the use of “extreme cruelty” within this VAWA special-rule should be read to encompass both physical and mental abuse, the Eleventh Circuit made a decisive move to recognize the effects of mental abuse on domestic violence victims beyond physical harm.