Unpub. BIA Remand Victory: CAT, Mexico, credibility, social group

"[T]he adverse credibility finding is clearly erroneous inasmuch as it based on minor inconsistencies and improper speculation (Resp. Br. at 15). See Ren v. Holder, 648 F.3d 1 (9th Cir. 2011) (trivial inconsistencies that under total circumstances have no bearing on petitioner's veracity should...

BIA on Social Group, Ghana (Unpub.)

"[R]espondent claims that he belongs to a particular social group consisting of individuals from Ghana who suffer from severe mental illnesses, such as bipolar disorder, and are indigent and lack family support. ... We conclude, based on the record before us in this case, that the respondent's...

New BIA Precedent Decisions on Social Group, Social Visibility

Both on Feb. 7, 2014: Matter of W-G-R-, 26 I&N Dec. 208 (BIA 2014) - (1) In order to clarify that the “social visibility” element required to establish a cognizable “particular social group” does not mean literal or “ocular” visibility, that element is renamed...

Unpub. BIA on Asylum, Mexico, Social Group, Gender Identity: Matter of M-G-O-

Ben Winograd writes: "In this unpublished decision, the Board of Immigration Appeals (BIA) found the respondent, a citizen of Mexico, qualified for withholding of removal based on his membership in a particular social group consisting of effeminate gay males with female gender identities. The Board...

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...