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Ninth Circuit on Past Persecution

March 01, 2007 (1 min read)

"Because the IJ did not make an adequate finding, one way or the other, on past persecution, we cannot determine whether the IJ applied a presumption of a well-founded fear of future persecution which the government would have been required to rebut." Hernandez v. Gonzales, Feb. 23, 2007.


Hernandez 9 2-23-07.pdf