Unpub. BIA Asylum Victory, Senegal, FGM

"Contrary to the Immigration Judge's finding (I.J. at 10-11), the fact that the respondent does not fear being subjected to female genital mutilation upon her return to Senegal is insufficient to rebut the presumption of future persecution.  Rather, an asylum applicant who has suffered female genital mutilation on account of a protected characteristic is presumed to risk future persecution on the basis of that protected characteristic, regardless of whether any future harm will likely be identical in form to the harm previously suffered.  See Matter of A-T-, 24 I&N Dec. 617 (A.G. 2008) (vacating in part Matter of A-T-, 24 I&N Dec. 296 (BIA 2007)).  Consequently, the respondent established her eligibility for asylum." - Matter of X-, Dec. 12, 2013.  [Hats off to Matthew L. Benson!]