"Ms. Ndeye Ndicke Seck, a native and citizen of Senegal, petitions for review of the Board of Immigration Appeals’ (“BIA’s”) final order, which affirmed an Immigration Judge’s decision to deny her application for withholding of removal under the Immigration and Nationality Act (“INA”), 8 U.S.C. § 1231(b)(3). Ms. Seck claims that if she returns to Senegal, it is more likely than not that she will be beaten or killed for attempting to protect her U.S. citizen daughter, B.D., from being subjected to female genital mutilation. We grant the petition for review because the BIA failed to give reasoned consideration to Ms. Seck’s application when it found she could relocate within Senegal to avoid persecution. We vacate the BIA’s decision with regard to Ms. Seck’s application for withholding of removal and remand for proceedings consistent with this opinion." - Seck v. Atty. Gen., Dec. 8, 2011.