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Court Denies Asylum for Failure to Meet Nexus, “Particularity” Prong

The First Circuit upheld BIA denials that the petitioner was targeted based on her family relationship and that “single mothers with no male protection who are unable to relocate in El Salvador” are a particular social group. The court also denied the CAT claim, affirming that the petitioner presented no evidence that a Salvadoran official would acquiesce to the petitioner’s torture by gang members.

CA3 Rejects “Social Visibility” and “Particularity” Concepts in Asylum

The court found that the addition of social visibility and particularity to the BIA’s social group definition is inconsistent with prior decisions and rejected it without a reason for adopting the requirements.

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