Decision date: 2022-10-24

Ruling that (1) Proposed PSG of "Salvadoran women who are witnesses to gang criminal activity and targeted because they filed a police report" lacked particularity and social distinction, (2) Petitioner was not a member of the proposed PSG of "Salvadoran women who are in a domestic relationship that they are unable to leave" because both of her past relationships had ended, and (3) Petitioner failed to offer any evidence of nexus between her past harm and family membership. The Court further declined to review the CAT claim because Petitioner did not raise it before the BIA.

Publication Status: Published

Case judge: Diaz, Wilkinson, Wynn

Decision: Morales v. Garland, 51 F.4th 553 (4th Cir. 2022)