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BIA on PSG, Persecution, Nexus: Matter of M-R-M-S-, 28 I&N Dec. 757 (BIA 2023)

December 04, 2023 (1 min read)

Matter of M-R-M-S-, 28 I&N Dec. 757 (BIA 2023) - If a persecutor is targeting members of a certain family as a means of achieving some other ultimate goal unrelated to the protected ground, family membership is incidental or subordinate to that other ultimate goal and therefore not one central reason for the harm. Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017), reaffirmed.

[Editor's Note: Please see former BIA Chairman Paul W. Schmidt's (always trenchant) commentary here.]