There are many ways that somebody who is here illegally can ultimately get their Green Card. For example, if the marriage is bonafide and you entered legally, but then fell out of status, you could adjust status in the U.S. (unless you entered on a C1/D visa.) Even then, while you might not qualify to adjust status, it is possible to be able to consular process with different types of waivers.
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Brian D. Lerner Immigration Attorney & Deportation Lawyer Blog 
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