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"[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 claimed social group constitutes a cognizable particular social group as contemplated by the Act. ... we will remand the record for further consideration of the respondent's applications for asylum, withholding of removal, and protection under the Convention Against Torture. In reevaluating the respondent's claim, the Immigration Judge should accept his asserted particular social group, allow testimony from his psychiatrist-and accept other testimonial and documentary materials that are pertinent to the above applications-and provide a clear and reasoned assessment as to whether the respondent qualifies for relief based on applicable case law and pursuant to current country conditions in Ghana." - Matter of X-, Nov. 15, 2013.
Hats off to Geoffrey A. Hoffman, Clinical Assoc. Professor, Director-University of Houston Immigration Clinic!