Help Salvadoran Brothers Evade Their Father’s Gang and Stay with Their Mother

Cristian* and Roberto* are 16- and 12-year-old boys from El Salvador. Their father, a member of a violent gang, left the home before Roberto was born and was eventually jailed for homicide. Cristian and Roberto came to the United States to join their mother after their caretaker aunt could no longer afford to care for them and received threats from their father. Cristian and Roberto now live with their mother in Maryland. Based on their father's neglect, Cristian and Roberto are eligible for Special Immigrant Juvenile Status (SIJS), a statutory form of relief that combines both state court and federal immigration components. Cristian and Roberto seek an attorney to represent them in all aspects of their SIJS proceedings. Alternatively, the boys fear returning to El Salvador because of their father’s gang and are eligible for asylum or withholding from removal.

 

All CAIR Coalition matters placed with a pro bono team are robustly mentored by a CAIR Coalition attorney.  Our mentoring program includes an opening meeting to discuss the scope and process of the matter, provision of samples, guidance on the law, review of draft filings, assistance with client contact, and guidance on preparation for interviews and hearings.  

 

*****

 

Cristian* and Roberto* are 16- and 12-year-old boys from El Salvador. Their father, a high-ranking member of a violent gang, left the home before Roberto was born, when Cristian was 3, and was eventually jailed for homicide. Neither Cristian nor Roberto have seen their father since and he never provided for them financially. The boys’ mother came to the United States in 2014 to provide for the boys and evade death threats by their father. She continued to speak with the boys daily and provided for them financially after departing.

 

After the boys’ mother moved to the United States, they stayed with various family members but eventually settled with their maternal aunt. The boys came to the United States in February 2020 because their maternal aunt could no longer afford to care for them and their father threatened to take them away when he gets out of jail. The boys are now reunited with their mother in Baltimore County, Maryland.

 

Cristian fears he would be brought into his father’s gang and taken away from his family if he were to return to El Salvador. Their father has threatened his mother’s life, abused her during their relationship, and has told Cristian that he will be out of jail soon. Roberto does not know the extent of his father’s threats or gang dealings, but his gang has watched and controlled the boys due to their father’s membership.

 

Cristian and Roberto are eligible for SIJS due to neglect by their father. SIJS is available to unaccompanied immigrant children under the age of 21 who have been abused, neglected, or abandoned, who cannot be reunified with one or both parents, and for whom returning to their home country is not in their best interest. SIJS requires three approvals, one from a state family court and two from USCIS. Because a state family court order is required, the attorney who represents Cristian and Roberto will need to be barred in Maryland or obtain court permission to appear pro hac vice. Alternatively, Cristian and Roberto will need an attorney to represent them in an asylum claim or in withholding from removal based on their fear of returning to El Salvador.

 

In order to assist Cristian and Roberto, a pro bono team will appear in state family court to obtain an order that the children meet the requirements for SIJS; prepare and submit SIJS application packages with United States Citizenship and Immigration Services; appear with the children at United States Citizenship and Immigration Services interviews, if required; and handle the adjustment of status paperwork. There also may be one or more brief scheduling hearings (“master calendar hearing”) with an Immigration Judge.

 

Currently, there are no hearings scheduled in Cristian and Roberto’s removal proceedings.

 

Cristian and Roberto speak Spanish and are living in Baltimore County, Maryland with their mother.

Timeline: As of September 23, 2020, there are no currently scheduled hearings in this case; State court custody hearings for SIJS ideally within 4 to 6 months, followed by USCIS filing (approvals can take 10 to 12 months).

          Location: Baltimore County, Maryland (not detained)

          Language: Spanish

 

For more information about this case, please contact Pro Bono Coordinating Attorney Jennifer Grishkin at jennifer@caircoalition.org or 202-866-9287.

 

*Pseudonyms are used to protect privacy

Sample?
No
Opportunity?
On

SIJS(MD)/Children’s Asylum: Help Brothers from El Salvador escape gang violence and remain with their mother.

Dax* and Elan* are 14- and 6-year-old children from El Salvador who want to remain in the United States with their mother. The brothers have different fathers, but Dax has never known his father, and Elan’s father abandoned him when Elan was only a year old. Neither child’s father communicates with them, and neither support them financially or emotionally. The brothers currently live in Baltimore County, Maryland with their mother. Based on their fathers’ abandonment, they are eligible for Special Immigrant Juvenile Status (SIJS), a statutory form of relief that combines both state court and federal immigration components. Dax and Elan need an attorney to represent each of them in all aspects of their SIJS proceedings. Additionally, the boys fear returning to El Salvador because a violent gang has threatened them and are eligible for asylum or withholding of removal.

All CAIR Coalition matters placed with a pro bono team are robustly mentored by a CAIR Coalition attorney.  Our mentoring program includes an opening meeting to discuss the scope and process of the matter, provision of samples, guidance on the law, review of draft filings, assistance with client contact, and guidance on preparation for interviews and hearings.  

******

Dax* and Elan* are 14- and 6-year-old children from El Salvador who want to remain in the United States with their mother. Dax’s mother conceived him when she was gang-raped. (Dax does not know this, and his mother does not want him to know.) Dax’s mother does not know the identity of her attackers, so she also does not know who Dax’s father is. She did, however, report the rape to the police.

 

Elan was abandoned by his father at the age of one. Elan’s father gave some financial support to Elan’s mother, but he did not financially or emotionally support Elan. Both Dax and Elan currently live in Baltimore County, Maryland with their mother.

 

 Before leaving El Salvador, the gang that raped Dax and Elan’s mother threatened her because she reported the rape to the police. When their mother left El Salvador, she left the children in the care of their abusive maternal grandmother (their mother was unaware of the abuse). Their aunt and uncle cared for them with church leaders, but they all fled in 2017 due to direct gang threats. The children would not have an adult to live with if they returned to El Salvador. Dax and Elan also are afraid to return to El Salvador because they have received death threats from the same gang that attacked and threatened their mother.

 

Based on their fathers’ abandonment, Dax and Elan are eligible for Special Immigrant Juvenile Status (SIJS), a statutory form of relief that combines both state court and federal immigration components. Dax and Elan need an attorney to represent them in all aspects of their SIJS proceedings and, alternatively, an asylum claim or withholding of removal based on their fear of returning to El Salvador.

 

SIJS is available to unaccompanied immigrant children under the age of 21 who have been abused, neglected, or abandoned, who cannot be reunified with one or both parents, and for whom returning to their home country is not in their best interest. SIJS requires three approvals, one from a state family court and two from USCIS. Because a state family court order is required, the attorney who represents these siblings will need to be barred in Maryland or obtain court permission to appear pro hac vice. 

 

In order to assist Dax and Elan, a pro bono team will appear in state family court to obtain an order that the children meet the requirements for SIJS; prepare and submit SIJS application packages with United States Citizenship and Immigration Services; appear with the children at United States Citizenship and Immigration Services interviews, if required; and handle the adjustment of status paperwork. There also may be one or more brief scheduling hearings (“master calendar hearing”) with an Immigration Judge. 

 

** Note about Joint representation: Dax does not know that he was conceived when his mother was gang-raped, and his mother does not want him to know it. This issue will require a sensitive and careful approach by the pro bono team.

   

Timeline: No scheduled Immigration Court hearings. State court custody hearing for SIJS ideally within 4 to 6 months, followed by USCIS filing (approvals can take 10 to 12 months). In response to COVID-19, the courts currently permit attorneys to attend all hearings telephonically. 

 

Location: Baltimore County, MD. 

 

Language: Spanish

 

For more information about this case, please contact Pro Bono Coordinating Attorney Jennifer Grishkin at jennifer@caircoalition.org or 202-866-9287.

*Pseudonyms are used to protect privacy

Sample?
No
Opportunity?
On

SIJS/Children’s Asylum: Guatemalan boy needs help escaping his abusive father.

Patricio* is a 14-year-old boy from Guatemala. Patricio is afraid to return to Guatemala because he believes he will be targeted by his abusive father, who is a gang member. Patricio’s father abused him and his mother until his parents separated when he was 3 years old. After the separation, Patricio’s father did not provide financially or keep in contact with Patricio. Since arriving in the US in 2020, Patricio has been living with his mother and aunt in Maryland. Due to the abuse and neglect of his father, Patricio is eligible for Special Immigrant Juvenile Status (SIJS), a statutory form of relief that combines both state court and federal immigration components. Patricio is looking for an attorney to represent him in all aspects of his SIJS proceedings and, alternatively, help him pursue Asylum or Withholding of Removal due to his fear of returning to Guatemala.

All CAIR Coalition matters placed with a pro bono team are robustly mentored by a CAIR Coalition attorney.  Our mentoring program includes an opening meeting to discuss the scope and process of the matter, provision of samples, guidance on the law, review of draft filings, assistance with client contact, and guidance on preparation for interviews and hearings.  

******

Patricio* is a 14-year-old boy from Guatemala. Patricio is afraid to return to Guatemala because he believes he will be targeted by his abusive father, who is a gang member. Patricio’s father abused him and his mother until his parents separated when he was 3 years old. Patricio’s father went as far as to threaten to kill both Patricio and his mother.  After the separation, Patricio’s father did not provide financially or keep in contact with Patricio.

 

Patricio’s mother went to the US when he was 11 years old. She sent money every two months and called Patricio three times a week. During that time, Patricio living with his maternal grandparents. Patricio’ grandparents are no longer viable caretakers because they are elderly and suffer health issues, including severe complications due to diabetes.

 

Since arriving in the US in 2020, Patricio has been living with his mother and his US-citizen aunt in Maryland. Due to the abuse and neglect of his father, Patricio is eligible for Special Immigrant Juvenile Status (SIJS), a statutory form of relief that combines both state court and federal immigration components. Patricio is looking for an attorney to represent him in all aspects of his SIJS proceedings and, alternatively, help him pursue Asylum or Withholding of Removal due to his fear of returning to Guatemala.

 

SIJS is available to unaccompanied immigrant children under the age of 21 who have been abused, neglected, or abandoned, who cannot be reunified with one or both parents, and for whom returning to their home country is not in their best interest. SIJS requires three approvals, one from a state family court and two from USCIS. Because a state family court order is required, the attorney who represents Patricio will need to be barred in Maryland or obtain court permission to appear pro hac vice. 

 

In order to assist Patricio, a pro bono team will appear in state family court to obtain an order that the children meet the requirements for SIJS; prepare and submit SIJS application packages with United States Citizenship and Immigration Services; appear with the children at United States Citizenship and Immigration Services interviews, if required; and handle the adjustment of status paperwork. There also may be one or more brief scheduling hearings (“master calendar hearing”) with an Immigration Judge. 

 

Timeline: No Immigration court hearings scheduled yet; State court custody hearing for SIJS ideally within 4 to 6 months, followed by USCIS filing (approvals can take 10 to 12 months). In response to COVID-19, the courts currently permit attorneys to attend all hearings telephonically.

 

Location: Montgomery County, MD.

 

Language: Spanish.

 

For more information about this case, please contact Pro Bono Coordinating Attorney Jennifer Grishkin at jennifer@caircoalition.org or 202-866-9287.

*Pseudonyms are used to protect privacy

Sample?
No
Opportunity?
On

Children’s Asylum: Guatemalan boy fears covid-related discrimination, threats, and targeted violence.

Sergio* is a 17-year-old boy from Guatemala. Sergio is afraid to return to Guatemala because of potential persecution for being a ‘contagiado’ (infected person). Even though Sergio has not tested positive for COVID-19, people coming from a country with high COVID-19 cases have been facing discrimination, threats, and violence in Guatemala. More specifically, people in Guatemalan Mayan villages have threatened repatriated migrants with lynching, burning their homes, attacking migrants’ families, and even burning the migrants out of fear they will spread the virus. To avoid this violence, Sergio is looking for an attorney to represent him in seeking asylum.

All CAIR Coalition matters placed with a pro bono team are robustly mentored by a CAIR Coalition attorney.  Our mentoring program includes an opening meeting to discuss the scope and process of the matter, provision of samples, guidance on the law, review of draft filings, assistance with client contact, and guidance on preparation for interviews and hearings.  

******

Sergio* is a 17-year-old boy from Guatemala. Sergio is afraid to return to Guatemala because of potential persecution for being a ‘contagiado’ (infected person). Even though Sergio has not tested positive for COVID-19, people coming from a country with high COVID-19 cases have been facing discrimination, threats, and violence in Guatemala. More specifically, people in Guatemalan Mayan villages have threatened repatriated migrants, who are perceived as infected, with lynching, burning their homes, attacking migrants’ families, and even burning the migrants out of fear they will spread the virus.

 

The government in Guatemala has been inadequate in handling the escalating violence and stigmatization of returned migrants and deportees. In fact, there are reports of government officials “egging on” the persecutors.

 

Sergio believes he will be specifically targeted if he returns because he is from a small village in Guatemala, where the majority of people know that he has been living in the United States for a year. Since the US has high number of cases, Sergio will likely be perceived as infected and thus subject to discrimination, threats, and violence. To avoid this, Sergio is looking for an attorney to represent him in seeking asylum. This case presents an opportunity to advance a novel asylum theory, supported by country conditions research and expert testimony, that could potentially help many similarly-situated children and adults.

 

Timeline: Sergio’s Master Calendar (scheduling) Hearing is 10/7/2020 at the Arlington Immigration Court. In response to COVID-19, the courts currently permit attorneys to attend all hearings telephonically.

 

Location: Detained in the DMV area. The detention shelter has a very solidified and organized system for communication with the minors remotely. Organizing appointments, getting signatures and photos, and other tasks relevant to this case are fairly easy to obtain through the program's case management system.

 

Language: Spanish (preferred) and Qeqchi

 

For more information about this case, please contact Pro Bono Coordinating Attorney Jennifer Grishkin at jennifer@caircoalition.org or 202-866-9287.

*Pseudonyms are used to protect privacy

Resource Type
Sample?
No
Opportunity?
On

Children's Asylum: Salvadoran Boy Fears Harm From Gang That Targeted His Family

Hector* is an 11-year-old boy from El Salvador who fears being returned to El Salvador due to threats of violence and death directed at all members of his family due to gangs wanting to extort money from his father. All of this comes in the wake of the murder of his uncle at the hands of the same gang members. Because of this history of past persecution of his family by these gangs, Hector likely qualifies for asylum based on family persecution.

 

 All CAIR Coalition matters placed with a pro bono team are robustly mentored by a CAIR Coalition attorney.  Our mentoring program includes an opening meeting to discuss the scope and process of the matter, provision of samples, guidance on the law, review of draft filings, assistance with client contact, and guidance on preparation for interviews and hearings.  

 

******

 

Hector* is an 11-year-old boy from El Salvador who fears being returned to El Salvador due to threats of violence and death directed at all members of his family due to gangs wanting to extort money from his father. All of this comes in the wake of the murder of his uncle at the hands of the same gang members. Although Hector never received threats himself, the threats were consistent and dangerous enough that Hector and his father fled to the United States.

 

Hector currently lives with his grandmother in Baltimore. She reports that the same men that are currently searching for and threatening Hector’s father, her son, are the same gang members who killed her other son. In 2010, these gang members approached her other son and his employer and demanded money of them. When they refused to give them money, the gang members killed them. The police were called and the gang members were arrested and jailed. The gang members are out of prison now, and they recently came searching for Hector’s father. When they first came looking for him, they were asking around in his neighborhood, although due to the small size and close-knit nature of the community, no one gave them any information. That did not stop them from continuing to come around looking for him. When her son notified the police, they told him to find an attorney to help him. Hector and his father came to the US a week after the family discovered that the gang had finally found them.

 

Despite this fear, Hector’s father had to return to El Salvador, leaving Hector with his grandmother, and Hector’s mother and sister were forced to relocate within El Salvador. Due to the widespread nature of the gang, all members of the family are still very afraid of these gang members.

 

Currently, there are no hearings scheduled in Hector’s removal proceedings. Hector speaks Spanish and is living in Baltimore, Maryland.

 

For more information about this case, please contact Pro Bono Coordinating Attorney Jennifer Grishkin at jennifer@caircoalition.org or 202-866-9287.

 

Timeline: No currently scheduled hearings. File asylum application within 4-5 months. In response to COVID-19, the courts currently permit attorneys to attend all hearings telephonically.

Location: Baltimore, Maryland. 

Language: Spanish

 

*Pseudonyms are used to protect privacy

Resource Type
Sample?
No
Opportunity?
On

Practice Pointers on Responding to Matter of A-B- in the Fourth Circuit (Added 2018)

 

Practice Pointers on Responding to Matter of

A-B- in the Fourth Circuit

 

On June 11, 2018, Attorney General Sessions issued his decision in Matter of A-B-, 27 I&N Dec 316 (A.G. 2018).  The case significantly changes the asylum law landscape.  It will be some time before all potential impacts of Matter of A-B- are understood, as litigants will test the case at the immigration court and appellate levels. 

 

This practice alert provides preliminary advice on affirmative steps to take for active asylum cases in the wake of Matter of A-B-.  As more guidance becomes available, we will update you and this practice alert.

 

WHAT IS MATTER OF A-B-?

 

Matter of A-B- is a decision by the Attorney General overruling a prior decision by the Board of Immigration Appeals (“BIA”) establishing asylum protection for women fleeing severe domestic violence.  The decision of the Attorney General:

 

  • Overruled BIA precedent establishing that women and girls who seek asylum based on domestic violence are eligible for asylum based on the particular social group of “married woman in Guatemala who are unable to leave their relationship” See, Matter of A-R-C-G, 26 I&N Dec. 338 (BIA 2014);

 

  • Held that if an asylum claim is flawed in one respect an adjudicator does not need to hold a hearing to examine the remaining elements of the claim;

 

  • Held that that the fact that a country may have problems policing certain crimes or that certain sub-sections of the population are more likely to be victims of crime is not the basis for an asylum claim; and,

 

  • Held that an applicant seeking to establish persecution based on conduct of a private actor must show that the government condoned the private actions or demonstrated an inability to protect the victims.

 

IS THIS THE END OF ASYLUM CASES?

 

No. The Attorney General’s interpretation of asylum law will certainly make many cases more difficult, especially those where the client is persecuted by a private actor. However, in the Capital Region there is still BIA precedent and Fourth Circuit precedent that you can use to make asylum arguments for asylum seekers who have been persecuted by private actors.

 

I HAVE A PENDING ASYLUM CASE FOR WHICH I HAVE ALREADY FILED MY BRIEFING. WHAT SHOULD I DO?

 

In an asylum case before an Immigration Judge, court rules allow you to supplement your briefing up to the date of the hearing with a motion requesting that the court accept a late filing. 

 

Similarly, for a children’s case at the asylum office, you may supplement your briefing at any time that is at least seven calendar days prior to the asylum interview.    

 

Ultimately, the decision whether to supplement is a strategic one that must be thought through carefully.  We recommend reviewing the case law outlined in this practice alert and speaking to your CAIR Coalition mentor regarding whether you should supplement your filing.

 

WHAT SHOULD I ARGUE IN GENERAL IN PREPARING MY CLIENT’S CASE?

 

There are two general-principle arguments that every asylum seeker in the Capital region should argue.  First, you should argue that Matter of A-B- should be applied narrowly and is inapplicable to your client’s case. Look for ways to distinguish your case from Matter of A-B- (See more below). 

 

Second, acknowledge Matter of A-B- but remind the adjudicator that Fourth Circuit law is the controlling authority and that it supersedes the AG’s decision. See below on which Fourth Circuit case law to assess for making this argument stronger.

 

For all cases, we also recommend taking the following steps in working with your client on their asylum case:

 

  • Do not rely on one formulation of a PSG.  Put forth all viable PSG formulations in your briefing at the immigration Court level, as is now essential under Matter of W-Y-C & H-O-B-, 27 I&N Dec. 189 (BIA 2018).  Any formulations not briefed at the immigration court level are likely waived and cannot be raised later.

 

  • Do not propose circular PSGs, those that are defined by the harm that your client faced.  For example, do not use "female Honduran youth who are trafficking victims" because it defines the group by the harm.

 

  • Ensure that you make a strong argument that your client is eligible for relief under the Convention against Torture (CAT), which does not require a protected ground. For more information on this, please contact your CAIR Coalition mentor.

 

  • Parse out the dicta and holdings in Matter of A-B – and distinguish dicta from holding.  The adjudicator in your case should not rely on the political or social statements made by the Attorney General.

 

  • Always preserve in the record for appeal an argument that Matter of A-B- is arbitrary and capricious and should not receive deference.

 

  • Secure a country conditions expert and country conditions evidence to shore up your arguments that your client’s persecution are not issues of generalized violence.  This helps overcome the holding that problems policing domestic violence/child abuse/gang violence/general violence are not enough to establish a basis for asylum.

 

  • Rely on Fourth Circuit law on nexus (the casual connection between persecution and protected ground), which holds differently than Matter of A-B-. See Zavaleta-Policiano v. Sessions, 873 F.3d 241 (4th Cir. 2017); Oliva v. Lynch, 807 F.3d 53 (4th Cir. 2015; Hernandez-Avalos v. Lynch, 784 F.3d 944, 947 (4th Cir. 2015); Temu v. Holder, 740 F.3d 887 (4th Cir. 2014).

 

  • With respect to private actors and the government’s willingness to control them, rely on Crespin-Valladares v. Holder, 632 F.3d 117 (4th Cir. 2012), which held the BIA’s analysis to be defective when it concluded that the Salvadoran government’s efforts to “focus[ ] law enforcement efforts on suppressing gang violence” was sufficient to show that the government was willing and able to control those private actors.  This is a factual question that must be addressed in each case.

 

WHAT SHOULD I ARGUE FOR MY CLIENT’S FAMILY-BASED ASYLUM CASE?

 

Acknowledge Matter of A-B- but articulate that your client’s claim is not impacted, as Crespin-Valladares v. Holder, 632 F.3d 117 (4th Cir. 2012) is binding Fourth Circuit law. Be sure to review Crespin-Valladares and Matter of L-E-A (BIA 2017).  Also review and cite to the good Fourth Circuit Court caselaw in this area in Hernandez-Avalos v. Lynch, 784 F. 3d 944 (4th Cir. 2015) and Cruz v. Sessions, 853 F.3d 122 (4th Cir. 2017).

 

 

WHAT SHOULD I ARGUE FOR MY CLIENT’S DOMESTIC VIOLENCE-BASED ASYLUM CASE?

 

Review the DHS brief from the pending BIA case Matter of L-R and the PSG formulation using the language about women viewed as property by virtue of their status in a domestic relationship. This PSG was not the basis for A-R-C-G but still has been accepted by adjudicators.     

 

You may also consider assessing the viability of about humanitarian asylum, which appeals to the adjudicator's discretionary powers.  Where asylum may not be viable, humanitarian asylum may be, though you still have to formulate a viable PSG. There are two ways to seek humanitarian asylum, either when the “applicant has demonstrated compelling reasons for being unwilling or unable to return to the country arising out of the severity of the past persecution,” or when the applicant “has established that there is a reasonable possibility that he or she may suffer other serious harm upon removal to that country.” 8 C.F.R. § 1208.13(b)(1)(iii)(A)-(B); Matter of L-S-, 25 I&N Dec. 705, 713 (BIA 2012); see also, Matter of Chen,  20 I&N Dec. 16 (BIA 1989).

 

WHAT SHOULD I ARGUE FOR MY CLIENT’S MENTAL HEALTH-BASED ASYLUM CASE?

 

Review CAIR Coalition case Temu v. Holder, 740 F.3d 887 (4th Cir. 2014).  Temu provides that the particular social group “individuals with bipolar disorder who exhibit erratic behavior” is immutable, particular, and socially visible, and not requiring ocular or “on sight,” visibility. The Fourth Circuit found that a group is socially distinct if it is singled out for worse treatment than other groups, countermanding the holding of Matter of A-B- that certain populations are more likely to be victims of crimeTemu further provides a strong basis to challenge the nexus analysis in Matter of A-B- where the Board fixates on the large size of a particular social group and conflates nexus with social visibility.  In Temu, simply because a particular social group is large, and that there is evidence that persecutors target the entire population, does not mean that it lacks social visibility. 

 

WHAT SHOULD I ARGUE FOR MY CLIENT’S GANG-BASED ASYLUM CASE?

 

Distinguish Matter of AB from your gang-based claim and rigorously define your PSG, and articulate compelling facts for nexus and the government's inability or unwillingness to protect your client. The INA and the Fourth Circuit long recognized that persecution encompasses harm from private actors. See, e.g., Hernandez-Avalos v. Lynch, 784 F. 3d 944 (4th Cir. 2015). Emphasize that Matter of A-B-'s central holding concerns domestic violence claims primarily, and the AG's reasoning with respect to gang-based claims does not depart from Board and Fourth Circuit precedent on PSG formulation, nexus, and the government's effective role in protecting victims. Recall that in the Fourth Circuit, nexus and the government's willingness or ability to control private actors are factual questions under Crespin-Valladares v. Holder, 632 F.3d 117 (4th Cir. 2012), which means that a well-developed record and on-point country conditions evidence will be pivotal.  

 

***

 

For more information, please contact your CAIR Coalition staff mentor or Kelly White at kelly@caircoalition.org or Michael Lukens at michael@caircoalition.org.

 

If you have an appeal pending before the BIA or the Fourth Circuit that may be impacted by Matter of A-B-, please reach out to Adina Appelbaum at adina@caircoalition.org for further guidance.

 

 

 

 

Attachment Size
Special Bulletin Matter of A-B-Final.pdf 691.75 KB
Categories
Secondary Resource Type
Sample?
Yes
Opportunity?
Off