"Linda Smith, a U.S. citizen, and “John Doe,” an undocumented
immigrant, had been a couple for more than nine years. When they decided
to marry, they could not obtain a marriage license from the Montgomery
County Probate Office...
"Respondent has established that Guatemalan women who are unable to leave a common law relationship is a particular social group. ... Considering these actions in context with the fact that most such violence in Guatemala is motivated by gender,...