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CA4 on Withholding, PSG, El Salvador, Chevron: Amaya v. Rosen

January 26, 2021 (1 min read)

Amaya v. Rosen

"[T]he only issue before us with respect to Amaya’s withholding claim is the narrow question of whether the PSG “former Salvadoran MS-13 members” is sufficiently particular. ... We are mindful that two of our sister circuits have determined that W-G-R- was reasonable, though we are unpersuaded by their reasoning to the extent it is relevant here. ... We grant Amaya’s petition in part and remand the BIA’s final order of removal. The BIA’s determination that “former Salvadoran MS-13 members” lacks particularity is unreasonable, and we thus remand Amaya’s withholding claim for the BIA to consider the IJ’s other holdings with respect to that claim."

[Hats off to Abdoul A. Konare!]