Document Type

Article

Publication Date

3-2019

Journal Title

North Carolina Journal of International Law

ISSN

0743-1759

Abstract

Part I of this Article provides a brief background about the evolution of the PSG ground in the United States and how it has become increasingly complicated and constricted over time. Part II discusses several ways that recent administrative decisions have imposed uniquely strict requirements for PSG-based asylum claims, both procedurally and substantively. Namely, the recent decision of the Board of Immigration Appeals ("BIA") in Matter of W-Y-C- & H-O-B- creates two new procedural restrictions. First, it imposes an exceedingly strict pleading standard in PSG cases by requiring "exact delineation" of the PSG. Second, Matter of W-Y-Cprohibits asylum seekers from revising their PSG in an administrative appeal, departing from longstanding practice. At the same time, the Attorney General's recent decision in Matter of A-B- imposes two significant substantive restrictions. It purports to exclude entire categories of claims from the PSG ground. Additionally, it imposes a heightened legal standard for showing persecution by non-governmental actors, which is especially common in gender-related cases brought under the PSG ground. Part III explores the significant implications of these recent developments

First Page

487

Last Page

517

Num Pages

31

Volume Number

44

Issue Number

3

Publisher

University of North Carolina School of Law

File Type

PDF

Share

COinS
 
 

To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.