BIA on Particular Social Group, Guatemala: Matter of A-R-C-G-

Official Headnote: Depending on the facts and evidence in an individual case, “married women in Guatemala who are unable to leave their relationship” can constitute a cognizable particular social group that forms the basis of a claim for asylum or withholding of removal under sections 208(a) and 241(b)(3) of the Immigration and Nationality Act, 8 U.S.C. §§ 1158(a) and 1231(b)(3) (2012)

Note: "... DHS now concedes the respondent established that she suffered past harm rising to the level of persecution and that the persecution was on account of a particular social group comprised of “married women in Guatemala who are unable to leave their relationship.” " - Matter of A-R-C-G-, 26 I&N Dec. 388 (BIA 2014) Interim Decision #3811

[Hats way off to Roy Petty and amici American Immigration Lawyers Association, Center for Gender & Refugee Studies, National Immigrant Justice Center, United Nations High Commissioner for Refugees and Williams & Connolly, LLP!]