The Ninth Circuit published a “particular social group” case this week, another salvo in the particular social group definition dialectic of the BIA and the Ninth Circuit Court of Appeals. The term “particular social group” relates to one of the five grounds for granting asylum, which I blogged about most recently here  and here. The most recent post was about two BIA cases, Matter of W-G-R- and Matter of M-E-V-G-, which addressed particular social group in the gang context. The…

Have you ever had the feeling that when someone is talking about one thing, in reality he is talking about something else? For example, a political leader may talk about some important principle that his country will never compromise about, which is a veiled warning to some other country, unnamed, that if it does not knock something off, it will pay a heavy price. Such is my feeling about two related Board of Immigration Appeals (BIA) cases that came out…

I last wrote about a case I thought would make a bigger splash than it did relating to voluntary departure. Today’s splashless big case is a case dealing with asylum, Henriquez-Rivas v. Holder, and in particular the term, “particular social group.” It is an en banc case in the Ninth Circuit published on February 13, 2013. By way of background, a person seeking asylum in the United States must show that he or she fears persecution in his or her…