Declining to rule on whether the Attorney General’s statement in Matter of L-E-A-, 27 I. & N. Dec. 581, 589 (A.G. 2019), that most nuclear families do not qualify as particular social groups, is entitled to deference in the Fourth Circuit. Reasoning that the BIA's decision in Petitioner's case did not rely on Matter of L-E-A- to find a lack of nexus because the BIA only referred to Matter of L-E-A- in a footnote.

Date of Decision