Decision date: 2018-12-21

Ruling that the BIA correctly denied Petitioner's motion to reopen on the basis of reinvigorating her previous claim of past persecution and asserting an individualized fear of future persecution, but that the BIA abused its discretion by failing to address Petitioner's new "pattern or practice" argument and new Cameroonian country conditions evidence indicating increased violence against Anglophones.

Publication Status: Unpublished

Case judge: Diaz, Hamilton, King

Decision: Sangi v. Whitaker, 757 F. App'x 247 (4th Cir. 2018) (No. 18-1616)