Seventh Circuit on trafficking victims, social group: Cece v. Holder (good dissent)

"Johana Cece, a citizen of Albania, petitions for review of a decision from the Board of Immigration Appeals upholding the denial of her application for asylum because she had not established membership in a particular social group. Cece argues on appeal that young Albanian women in danger of being trafficked for prostitution constitute a social group. Her proposed group, however, is defined solely by the persecution feared by its members and lacks the type of common, immutable characteristics otherwise required of a particular social group. Moreover, substantial evidence supports the Board’s conclusion that Cece has not established a well-founded fear of persecution if she returns to Albania. Accordingly, we deny the petition for review." - Cece v. Holder, Feb. 6, 2012. [But see Rovner's dissent.]