Ep. 221 - Precedential Decisions from 7/15/2024 - 7/21/2024 (flight from ethnic cleansing & genocide; gang recruitment & PSGs; CIMT & prostitution; I-213 reliability; unfulfilled threat doctrine)

Paye v. Garland, No. 23-1426 (1st Cir. July 17, 2024)

• flight from ethnic cleansing and genocide as past persecution; INA § 242(a)(2)(C) jurisdiction

Ramos-Gutierrez v. Garland, No. 23-1885 (1st Cir. July 18, 2024)

• particularly social group; nexus; circularity; example of what happens when you report on gangs in El Salvador 

Ortega-Cordova v. Garland, No. 22-1700 (4th Cir. July 16, 2024)

• evolving definition of CIMT; solicitation of prostitution in violation of VA Code § 18.2-346(B); federal definition of a felony; 18 U.S.C. § 3559(a)

Vera Punin v. Garland, No. 22-6275 (2d Cir. July 16, 2024)

• I-213; clear and convincing evidence; exhaustion of arguments; inherently reliable; alienage burden; temporary BIA member appointment exceeding six months

KC v. Garland, No. 20-3043 (2d Cir. July 17, 2024)

• unfulfilled-threat doctrine; cumulative or aggregate past persecution analysis; death threats; aggravating factors; threats against family

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