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Amanda Gray writes: "I wanted to share this great withholding decision I received today. The BIA reversed [an IJ in] Salt Lake City in a detained withholding / CAT case (client is in Tacoma, WA in withholding only proceedings) on the grounds that my client had suffered past persecution at the hands of local [Mexican] police on account of his imputed nationality as a U.S. citizen. The BIA remanded to the IJ to give DHS the opportunity to establish changed country conditions or that internal relocation would be reasonable but noted that when the persecutor is the government it is presumed that internal relocation would not be reasonable."
[Hats off to Amanda!]