Immigration Law

Recent Posts

CA1 on Family PSG: Enamorado-Rodriguez v. Barr
Posted on 31 Oct 2019 by Daniel M. Kowalski

Enamorado-Rodriguez v. Barr "Darlin Eleazar EnamoradoRodriguez ("Enamorado"), a Honduran national, came to the United States at age fifteen and sought asylum, withholding of removal, and protection under the Convention Against Torture... Read More

Boston Immigration Judge Grants Asylum; PSG = "Guatemalan Women"
Posted on 8 Aug 2019 by Daniel M. Kowalski

Boston Immigration Judge Paul M. Gagnon granted asylum in a DV-based case, recognizing "Guatemalan women" as a particular social group. ICE reserved, but did not appeal, so the decision is final . The IJ addressed Matter of A-B- in several places... Read More

Materials Related to L-E-A-
Posted on 31 Jul 2019 by Daniel M. Kowalski

Link to the July 29, 2019 A.G. decision here . Link to briefs and other materials collected by CLINIC Legal here . Read More

A.G. Barr on 'Particular Social Group' - Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019)
Posted on 31 Jul 2019 by Daniel M. Kowalski

Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019) (1) In Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017), the Board of Immigration Appeals improperly recognized the respondent’s father’s immediate family as a “particular social group”... Read More

CA7 on Asylum, Mexico, Cartel Violence: Gonzalez Ruano v. Barr
Posted on 25 Apr 2019 by Daniel M. Kowalski

Gonzalez Ruano v. Barr "In September 2016, members of a Mexican drug cartel kidnapped, tortured, and threatened to kill petitioner Mauricio Gonzalez Ruano, who was living with his family in the Mexican state of Jalisco. ... We find that the record... Read More

IJ Eileen Trujillo Recognizes “Women in Mexico” as PSG, Finds Nexus, Grants Asylum, Distinguishes A-B-
Posted on 22 Mar 2019 by Daniel M. Kowalski

Paul W. Schmidt, Mar. 21, 2019 "JUSTICE PREVAILS AGAIN IN IMMIGRATION COURTS EVEN IN THE “POST-A-B-“ ERA — Outstanding Analysis By Judge Eileen Trujillo Of The U.S. Immigration Court In Denver, CO, Recognizes “Women In Mexico”... Read More

Mexican Asylum Grant by IJ Trujillo in Denver
Posted on 27 Dec 2018 by Daniel M. Kowalski

James S. Lamb writes: "Nuclear family PSG and a quasi-non-state persecutor (quasi, on account of government corruption and involvement of certain officials). Case is pre-Matter of A-B-. ... fact heavy ... Trujillo wrote a good opinion ." Read More

A.G. on Persecution, Social Group, Family Unit: Matter of L-E-A-, 27 I&N Dec. 494 (A.G. 2018)
Posted on 4 Dec 2018 by Daniel M. Kowalski

Matter of L-E-A-, 27 I&N Dec. 494 (A.G. 2018) BEFORE THE ACTING ATTORNEY GENERAL Pursuant to 8 C.F.R. § 1003.1(h)(1)(i), I direct the Board of Immigration Appeals (“Board”) to refer this case to me for review of its decision.... Read More

Matter of A-B-, 27 I&N Dec. 227 (A.G. 2018)
Posted on 7 Mar 2018 by Daniel M. Kowalski

Matter of A-B-, 27 I&N Dec. 227 (A.G. 2018) - The Attorney General referred the decision of the Board of Immigration Appeals to himself for review of issues relating to whether being a victim of private criminal activity constitutes a cognizable “particular... Read More

Kinship as Particular Social Group: Guatemalan CAT/Withholding Victory at Berks Immigration Court
Posted on 30 May 2015 by Daniel M. Kowalski

"The pernicious problem of gender-based violence in Guatemala is a complex phenomenon. But at its core lies the inescapable fact that women in Guatemala are generally viewed as subservient to men and according to the police, unworthy of its protections... Read More

BIA on Family as Particular Social Group - Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017)
Posted on 24 May 2017 by Daniel M. Kowalski

Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017) - (1) Whether a particular social group based on family membership is cognizable depends on the nature and degree of the relationships involved and how those relationships are regarded by the society in... Read More

CA9 on 'Particular Social Group' - Bringas-Rodriguez II (en banc)
Posted on 9 Mar 2017 by Daniel M. Kowalski

Bringas-Rodriguez v. Sessions, Mar. 8, 2017 - "Carlos Alberto Bringas-Rodriguez (Bringas), a gay man who is a native and citizen of Mexico, petitions for review of the Board of Immigration Appeals’ (BIA) denial of his applications for asylum... Read More

BIA Calls for Amicus Briefs on Family as Particular Social Group - Deadline Feb. 10, 2016
Posted on 11 Jan 2016 by Daniel M. Kowalski

BIA, Jan. 11, 2016 - "The Board of Immigration Appeals welcomes interested members of the public to file amicus curiae briefs discussing the below issue: ISSUES PRESENTED: (1) Where an asylum applicant has demonstrated persecution because of... Read More

DHS Brief in Matter of L-A- (Family as PSG)
Posted on 12 May 2016 by Daniel M. Kowalski

CLINIC (Bradley Jenkins) writes: "CLINIC recently received word from counsel of record in Matter of L-A- (also known as the "family as particular social group" amicus invitation from the Board ) that DHS has filed their supplemental brief... Read More

Update on New and Novel PSGS: USCIS, Apr. 15, 2015
Posted on 24 Apr 2015 by Daniel M. Kowalski

A Washington Times article references a 27-page document on the 'particular social group' (PSG) aspect of asylum adjudications, discussed during an April 23, 2015 Senate Judiciary Committee hearing . The document, dated April 15, 2015 and entitled... Read More