Unpub. BIA Asylum Victory, 'Changed Personal Circumstances' - Matter of Chen

"While we agree with the Immigration Judge that "changed personal circumstances" do not, in and of themselves, constitute an exception to the filing deadline for asylum, we recognize that changed personal circumstances may form the basis of an exception under section 208(a)(2)(D) of the Act. ... In the present matter, although the respondent practiced Christianity prior to her arrival in the United States in 2002, she credibly testified that she did not fear returning to China on account of her Christian religion until learning of her mother's arrest by Chinese officials in 2010. ... Because the arrest of her mother gave rise to her subjective fear of returning to China, we conclude that such arrest constitutes a changed circumstance that materially affects her eligibility for asylum." - Matter of Chen, Feb. 1, 2013, unpub.  [Hats off to Alan Lee!]