Exigent grounds for adjustment of immigration status do not repoen the filing period for the claim.
Sua sponte decisions of whether to open a case are unreviewable absent colorable constitutional or legal claims.
Past agency adjudication holding that the agency would modify procedures where a claimant was prima facie eligible antedates the current rules and does not make the present holding arbitrary and capricious.
http://media.ca1.uscourts.gov/pdf.opinions/17-2068P-01A.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.