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NIJC Particular Social Group Practice Advisory


UNHCR Guidelines


U.S. Courts of Appeals Briefs

Henriquez-Rivas v. Holder (9th Circuit) amicus briefs:

Rivera Barrientos v. Holder: National Immigrant Justice Center amicus brief

Cece v. Holder (7th Circuit): National Immigrant Justice Center amicus brief

Santos v. Holder (3rd Circuit): National Immigrant Justice Center amicus brief


Board of Immigration Appeals

Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017)

  • NIJC amicus brief (asserting that in a particular social group-based asylum claim, the adjudicator should primarily focus on the nexus element - rather than the social group definition - and ask why the applicant was or will be harmed).

C-R-P-: NIJC amicus brief


Perdomo: Board of Immigration Appeals ruling

Matter of RA: Department of Homeland Security brief

Matter of LR: Department of Homeland Security brief

Matter of A-C-G-: Department of Homeland Security motion to remand


Immigration Court

El Salvador witness claim: 


Other NIJC resources on PSG


Additional Relevant Case Law

Seventh Circuit

  • Orejuela v. Gonzales, 425 F.3d 666 (7th Cir. 2005) (PSG: the educated, landowning class of cattle farmers [in Colombia])
  • Gatimi v. Holder, 578 F.3d 611 (7th Cir. 2009) (PSG: former members of the Mungiki)
  • Benitez Ramos v. Holder, 589 F.3d 426 (7th Cir. 2009) (PSG: tattooed, former Salvadoran gang members)
  • Sarhan v. Holder, 658 F.3d 649 (7th Cir. 2011) (PSG: Jordanian women who, in accordance with social and religious norms in Jordan, are accused of being immoral criminals)
  • Escobar v. Holder, 657 F.3d 527 (7th Cir. 2011) (PSG: former truckers [in Colombia] who resisted the FARC and collaborated with the government)
  • Cece v. Holder, 733 F.3d 662 (7th Cir. 2013) (PSG: young, Albanian women who live alone)
  • N-L-A- v. Holder, No. 11-2706 (7th Cir., Mar. 3, 2014) (PSG: landowners of means who had refused to cooperate with the FARC)

Other Circuits

  • Garcia v. U.S. Att’y Gen., 665 F.3d 496 (3d Cir. 2011) (PSG: individuals who testify against gang members)
  • Valdiviezo-Galdamez v. Holder, 663 F.3d 582 (3d Cir. 2011) (PSG: young men who have been actively recruited by gangs and who have refused to join the gangs” is a “particular social group)
  • Crespin-Valladares v. Holder, 632 F.3d 117 (4th Cir. 2011) (PSG: family members of those who actively oppose gangs in El Salvador by agreeing to be prosecutorial witnesses)
  • Martinez v. Holder, 740 F.3d 902 (4th Cir. 2014) (PSG: former gang members)
  • Perdomo v. Holder, 611 F.3d 662 (9th Cir. 2010) (PSG: Guatemalan women)
  • Henriquez-Rivas v. Holder, 707 F.3d 1081 (9th Cir. 2013) (PSG: people who testify against gang members)
  • Cordoba v. Holder, 726 F.3d 1106 (9th Cir. 2013) (PSG: landowners in X country)
  • Niang v. Gonzales, 422 F.3d 1187 (10th Cir. 2005) (PSG: females within a particular tribe)

Board of Immigration Appeals

  • Matter of Acosta, 19 I&N Dec. 211 (BIA 1985) (establishes the asylum definition)
  • Matter of H-, 21 I&N Dec. 337 (BIA 1996) (PSG: Somali clans)
  • Matter of C-A-, 23 I&N Dec. 951 (BIA 2006) (PSG: former noncriminal drug informants working against the Cali drug cartel)
  • Matter of S-E-G-, 24 I&N Dec. 579 (BIA 2008) (PSG: Salvadoran youths who have resisted gang recruitment, or family members of such Salvadoran youth)
  • Matter of E-A-G-, 24 I&N Dec. 591 (BIA 2008) (PSG: young persons who are perceived to be affiliated with gangs)
  • Matter of M-E-V-G-, 26 I&N Dec. 227 (BIA 2014) (Valdiviezo on remand from the Third Circuit)
  • Matter of W-G-R-, 26 I&N Dec. 20 (BIA 2014) (PSG: former members of the Mara 18 gang in El Salvador who have renounced their gang membership)