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In this case the applicant, a child, was subject to abuse - the question was whether the abuse rose to the level of past persecution.  By published opinion, Judge Flaum agreed with our position that it is relevant to past persecution whether an individual was a minor at the time of events, but upheld the Board’s denial under the deferential substantive evidence standard.

Read the Seventh Circuit Court of Appeals opinion, 380 F.3d 307, 312 (7th Cir. 2004).