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United States Second Circuit


Paloka v. Holder, 12-4987

Order of the Board of Immigration Appeals (BIA) dismissing petitioner's application for asylum is remanded, where: 1) petitioner, a young Albanian woman between ages 15 and 25, argues that this group qualifies as a "particular social group" for asylum purposes under 8 U.S.C. section 1101(a)(42)(A); 2) the BIA clarified its interpretation of "particular social group" in precedential opinions following the original petition, requiring that asylum seekers demonstrate that their group is perceived by society to be distinct, that their group is discrete, not amorphous or subjective, and that they were persecuted because of their membership in such group; and 3) petitioner refined her particular social group upon appeal, specifying an age range.

Appellate Information

  • Decided 08/07/2014
  • Published 08/07/2014

Judges

  • Newman

Court

  • United States Second Circuit

Counsel

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