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Matter of O-F-A-S-, 28 I&N Dec. 35 (A.G. 2020)
(1) Under Department of Justice regulations implementing the Convention Against Torture, an act constitutes “torture” only if it is inflicted or approved by a public official or other person...
Iruegas-Valdez v. Yates, Jan. 23, 2017 - ""[W]illful blindness” is not the only way to prove sufficient state action. The regulations specifically list a number of different avenues which the BIA failed to consider: torture occurs whenever...
"The IJ and BIA denied CAT protection because Garcia admitted that he could not be sure whether the extortionists were actually police officers, or whether they were criminals impersonating police officers, and because Garcia did not report the incidents...