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Interim Decision #4203

Matter of S-E-M-Z-, Applicant

Decided June 5, 2026

U.S. Department of Justice

Executive Office for Immigration Review

Board of Immigration Appeals

The “social distinction” element of a particular social group must generally be measured

on a countrywide basis, rather than from the perspective of a neighborhood or other limited

geographic location within a country.

FOR THE APPLICANT: Jarom J. Yates, Esquire, Dallas, Texas

FOR THE DEPARTMENT OF HOMELAND SECURITY: Stacy Norcross, Assistant

Chief Counsel

BEFORE: Board Panel: MALPHRUS, Chief Appellate Immigration Judge; GEMOETS,

Appellate Immigration Judge; MCCLOSKEY, Temporary Appellate Immigration Judge.

GEMOETS, Appellate Immigration Judge:

The Department of Homeland Security (“DHS”) appeals from an

Immigration Judge’s March 5, 2019, decision granting the applicant’s

request for withholding of removal pursuant to section 241(b)(3) of the

Immigration and Nationality Act (“INA”), 8 U.S.C. § 1231(b)(3) (2018).

The applicant opposes the appeal. The appeal will be sustained, and the

record will be remanded.

I. FACTUAL AND PROCEDURAL BACKGROUND

The applicant is a native and citizen of Honduras who is in

withholding-only proceedings. In October 2016, MS-13 gang members

attempted to recruit the applicant’s daughter to sell drugs on their behalf, be

a prostitute, and otherwise further their criminal enterprise. They threatened

to kill the applicant because she opposed her daughter’s recruitment.

The applicant’s daughter was kidnapped in October 2016. The applicant,

her nephew, and a young man were able to locate the applicant’s daughter.

The nephew then drove the applicant and her daughter to a rural village

where the applicant’s mother lived. Strangers who were perceived as gang

members arrived at the village asking about the applicant. The applicant and

her daughter then left Honduras for the United States. The nephew who

helped locate the applicant’s daughter was found murdered thereafter.

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The Immigration Judge concluded that the applicant experienced past

persecution in Honduras on account of her membership in a family-based

particular social group, that Honduran authorities were unable or unwilling

to protect her, and that DHS did not rebut the resulting regulatory

presumption that her life or freedom would be threatened in the future in

Honduras for the same reason.

II. ANALYSIS

A. Membership in a Particular Social Group

DHS argues that the applicant’s family-based particular social group is

not cognizable. For the following reasons, we agree. 1

A legally cognizable particular social group requires immutable

characteristics, must be defined with particularity, and must be socially

distinct within the society in question. Matter of W-G-R-, 26 I&N Dec. 208,

212–18 (BIA 2014), vacated in part on other grounds sub nom., Reyes v.

Lynch, 842 F.3d 1125 (9th Cir. 2016). In Matter of L-E-A- II, the Attorney

General held that an applicant’s immediate family “generally will not be

distinct on a societal scale, whether or not it attracts the attention of criminals

who seek to exploit that family relationship in the service of their crimes.”

27 I&N Dec. at 582. In order “to qualify under the statute and Board

precedent, when an applicant proposes a group composed of a specific family

unit, he must show that his proposed group has some greater meaning in

society.” Id. at 594. “It is not enough that the family be set apart in the eye

of the persecutor, because it is the perception of the relevant society—rather

1

In finding that the particular social group was cognizable, the Immigration Judge

expressly relied on our decision in Matter of L-E-A-, 27 I&N Dec. 40 (BIA 2017)

(“L-E-A- I”). In that case, we held that “family ties may meet the requirements of a

particular social group depending on the facts and circumstances in the case.” Matter of

L-E-A- I, 27 I&N Dec. at 42. During the pendency of this appeal, the Attorney General

overruled Matter of L-E-A- I. Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019)

(“L-E-A- II”). That decision, in turn, was overruled for a time by Matter of L-E-A-, 28 I&N

Dec. 304 (A.G. 2021) (“L-E-A- III”). However, the Attorney General recently vacated

Matter of L-E-A- III and instructed adjudicators to adhere to the holding of Matter of

L-E-A- II in all pending and future claims. Matter of R-E-R-M- & J-D-R-M-, 29 I&N Dec.

202, 205 (A.G. 2025). Accordingly, we analyze this claim through the holding of Matter

of L-E-A- II. The same applies to the Attorney General’s decisions in Matter of A-B-,

27 I&N Dec. 316 (A.G. 2018) (“A-B- I”), and Matter of A-B-, 28 I&N Dec. 199

(A.G. 2021) (“A-B- II”). See Matter of S-S-F-M-, 29 I&N Dec. 207 (A.G. 2025)

(reinstating Matter of A-B- I and Matter of A-B- II).

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than the perception of the alien’s actual or potential persecutors—that

matters.” Id.

In determining that the applicant established a valid family-based

particular social group, the Immigration Judge found that people within

Honduran neighborhoods know each other and are highly familiar with the

details of families within those neighborhoods. While this finding is

grounded in the record and is not clearly erroneous, the Immigration Judge

erred by focusing on a specific neighborhood to determine the concept of

social distinction, instead of the relevant society at large. “The fact that

nuclear families or some other widely recognized family unit generally carry

societal importance says nothing about whether a specific nuclear family

would be recognizable by society at large.” Matter of L-E-A- II, 27 I&N Dec.

at 594 (citation modified). An immediate family must carry “greater societal

import” in order to meet the social distinction requirement. Id. at 595. We

recognize that neighbors within a limited geographic and residential area

may be known to each other; however, such recognition does not establish

that, for asylum and withholding of removal claims and in the case of a

specific family, such family unit is recognized as separate and distinct by

society at large. Adherence to this scope of inquiry is consistent with the

concept of a refugee as being unable to return to a country as opposed to a

solitary neighborhood or limited geographic location within such country.

INA § 101(a)(42); 8 U.S.C. § 1101(a)(42) (2018).

Our prior precedents do not support the conclusion that social distinction

can be measured from the perspective of a neighborhood. We first addressed

the definition of “particular social group” in Matter of Acosta, 19 I&N Dec.

211 (BIA 1985), overruled on other grounds by Matter of Mogharrabi,

19 I&N Dec. 439 (BIA 1987). In Matter of Acosta, we held that members of

such a group must “share a common, immutable characteristic.” Id. at 233.

As this case focused on the concept of immutability, we had no reason to

explicitly address how a relevant society perceives a claimed particular social

group. However, we emphasized the significance of fear-based protection

that “a refugee must be unable or unwilling to return to a particular

‘country.’”

Id. at 235 (citing INA § 101(a)(42)(A), 8 U.S.C.

§ 1101(a)(42)(A)). “[A]n alien seeking to meet the definition of a refugee

must do more than show a well-founded fear of persecution in a particular

place or abode within a country—he must show that the threat of persecution

exists for him country-wide.” Id. (emphasis added).

In subsequent cases, we focused, among other matters, on society’s

perception, using varying terms to describe this requirement. For example,

we noted the “distinct and recognizable clans and subclans in Somalia.”

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Matter of H-, 21 I&N Dec. 337, 343 (BIA 1996) (emphasis added). In Matter

of C-A-, 23 I&N Dec. 951, 959–60 (BIA 2006), aff’d sub nom.,

Castillo-Arias v. U.S. Att’y Gen., 446 F.3d 1190 (11th Cir. 2006), we held

that “‘visibility’ is an important element in identifying the existence of a

particular social group” and for such group’s recognizability. We concluded

that “noncriminal informants working against the Cali drug cartel” in

Colombia were not a particular social group in part because the group was

not visible to the society in question. Id. at 961.

We later stated that “[w]hether a proposed group has a shared

characteristic with the requisite ‘social visibility’ must be considered in the

context of the country of concern and the persecution feared.” Matter of

A-M-E- & J-G-U-, 24 I&N Dec. 69, 74 (BIA 2007), aff’d sub nom., UceloGomez v. Mukasey, 509 F.3d 70 (2d Cir. 2007). We subsequently clarified

that the term “‘visibility’ unintentionally promoted confusion.” Matter of

W-G-R-, 26 I&N Dec. at 216. We thus renamed “that requirement ‘social

distinction’ to clarify that social visibility does not mean ‘ocular’ visibility—

either of the group as a whole or of individuals within the group—any more

than a person holding a protected religious or political belief must be

‘ocularly’ visible to others in society.” Id. In a companion case, we held that

“a group’s recognition for asylum purposes is determined by the perception

of the society in question, rather than by the perception of the persecutor.”

Matter of M-E-V-G-, 26 I&N Dec. 227, 242 (BIA 2014). We have applied

this framework ever since. See also Matter of A-B- I, 27 I&N Dec. at 336

(“But the key thread running through the particular social group framework

is that social groups must be classes recognizable by society at large.”).

In asylum and withholding of removal claims, consideration of a

particular social group designation is constricted to the applicant’s relevant

society and the past harm experienced and prospective harm feared therein.

This reference to society must be viewed within its statutory context of

nationwide persecution, which is a fundamental aspect of fear-based relief.

As noted in Matter of Acosta, “inherent in refugee status is the concept that

an individual requires international protection because his country of origin

or of habitual residence is no longer safe for him.” 19 I&N Dec. at 235;

accord INA § 241(b)(3)(A), 8 U.S.C. § 1231(b)(3)(A) (establishing that for

withholding of removal under the INA, “the Attorney General may not

remove an alien to a country if the Attorney General decides that the alien’s

life or freedom would be threatened in that country because of the alien’s

race, religion, nationality, membership in a particular social group, or

political opinion”) (emphasis added). See generally Robinson v. Shell Oil

Co., 519 U.S. 337, 341 (1997) (looking “to the language itself, the specific

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context in which that language is used, and the broader context of the statute

as a whole”).

Additionally, the regulations specifically require adjudicators to

determine whether applicants can reasonably relocate within their country.

8 C.F.R. §§ 1208.13(b), 1208.16(b) (2020); see Matter of D-I-M-, 24 I&N

Dec. 448, 449–51 (BIA 2008) (discussing the relevant regulatory framework

for asylum eligibility). In this regard, adjudicators must deny asylum in the

exercise of discretion, even if an applicant has established past persecution

on account of a protected ground, if DHS can establish that the “applicant

could avoid future persecution by relocating to another part of the applicant’s

country of nationality or, if stateless, another part of the applicant’s country

of last habitual residence, and under all the circumstances, it would be

reasonable to expect the applicant to do so.” 8 C.F.R. § 1208.13(b)(1)(i)(B).

A focus on whether a proposed group is socially distinct within a

neighborhood or other limited geographic location within a country is

inconsistent with the purpose of nationwide protection contemplated by

asylum and statutory withholding of removal. Merely focusing on a limited

geographic location begs the question of why that group is not distinct

amongst a larger population. It would be anomalous to conclude that a

particular social group is socially distinct within a single neighborhood,

without consideration of the group’s distinction amongst the broader society.

By comparison, claims that may arise from religion or political opinion,

separate and distinct protected grounds, are not limited by a small geographic

location of identity or mistreatment, but considered in the context of

nationwide harm.

“[T]he requirements for ‘membership in a particular social group’ are

consistent with the other grounds of persecution, [and] the overall burdens

are equivalent to those placed on applicants asserting claims based on the

other grounds.” Matter of M-E-V-G-, 26 I&N Dec. at 244. We have long

held that an asylum claim based on nongovernmental action is not

“adequately established where the evidence the respondent presents is

directed to so local an area of his country of nationality.” Matter of Fuentes,

19 I&N Dec. 658, 663 (BIA 1988). We also have held that “a political

opinion under the INA must be tethered to an expression of a belief or

conviction regarding a discrete cause related to the government of a country,

or . . . a de facto government.” Matter of D-G-E-A- & N-G-G-E-, 29 I&N

Dec. 570, 575–76 (BIA 2026) (emphasis added). It would render the concept

of social distinction meaningless if review is limited to a minimal geographic

location where neighbors are familiar with one another but lack that similar

familiarity outside the location within their country.

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As in this case, treating a neighborhood or other limited geographic

location as the relevant society for the social distinction inquiry is

inconsistent with the INA’s focus on countrywide persecution. It is also

inconsistent with the well-established principle that an asylum applicant

“must show that the threat of persecution exists for him country-wide.”

Matter of Acosta, 19 I&N Dec. at 235. As noted, adjudicators cannot grant

asylum without considering whether relocation within the country is

reasonably possible. See, e.g., 8 C.F.R. § 1208.13(b)(1)(i). Accordingly, we

conclude that social distinction must generally be measured on a countrywide

basis, rather than from the perspective of a neighborhood or other limited

geographic location within a country.

Circuit court decisions routinely refer to a nation’s society. See AmezcuaPreciado v. U.S. Att’y Gen., 943 F.3d 1337, 1344 (11th Cir. 2019) (“Further,

nothing in the country conditions evidence indicates that AmezcuaPreciado’s proposed social group is socially distinct within Mexican

society.”); Rivera-Barrientos v. Holder, 666 F.3d 641, 653 (10th Cir. 2012)

(“Rivera Barrientos has offered no evidence to suggest that Salvadoran

society considers young women who have resisted gang recruitment to be a

distinct social group.”); Conde Quevedo v. Barr, 947 F.3d 1238, 1243 (9th

Cir. 2020) (“Nor, critically, does any of those documents assert that

Guatemalan society recognizes those who, without more, report gang

violence as a distinct group.”); Lemus-Coronado v. Garland, 58 F.4th 399,

402 (8th Cir. 2023) (“We agree with the [Board] that [the applicant] has

failed to demonstrate that ‘witnesses who cooperate with law enforcement’

is recognized as a socially distinct group within Guatemalan society and thus

deny the petition.”); Zaldana Menijar v. Lynch, 812 F.3d 491, 500 (6th Cir.

2015) (“Like Zaldana’s documentary evidence, his proffered testimony fails

to undermine the agency’s conclusion that ‘active and long-term former gang

members’ lacked the requisite social distinction within Salvadoran

society.”); Gonzales-Veliz v. Barr, 938 F.3d 219, 232 (5th Cir. 2019)

(“Gonzales-Veliz has similarly failed to explain how Honduran society views

women unable to leave their relationship as a socially distinct group.”);

Morales v. Garland, 51 F.4th 553, 557–58 (4th Cir. 2022) (“It is not enough

that members of the proposed group see themselves as socially distinct.

What matters is the view of Salvadorean society as a whole.”); S.E.R.L. v.

Att’y Gen. U.S., 894 F.3d 535, 556–57 (3d Cir. 2018) (“S.E.R.L. fails to

direct us to anything in the record . . . that would compel the conclusion that

Honduran society perceives immediate family members of women who

cannot leave domestic relationships as constituting a socially distinct

group.”); Quintanilla-Mejia v. Garland, 3 F.4th 569, 590 (2d Cir. 2021)

(“While [there] may be some evidence that the Salvadoran [G]overnment

views former gang members as socially distinct—at least to the extent that

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they were the primary beneficiaries of the tattoo-removal program—it does

not compel the conclusion that Salvadoran society as a whole viewed gang

members who participated in the program as socially distinct.”); EspinozaOchoa v. Garland, 89 F.4th 222, 235 (1st Cir. 2023) (“We leave it to the

[Board] to decide in the first instance whether Espinoza-Ochoa’s social

group is socially distinct in Guatemalan society, consistent with this

opinion.”). These cases include countries with large, diverse populations and

geographic footprints, as well as smaller, less-populated countries. They do

not indicate that a neighborhood can be a relevant society for measuring

social distinction.

We acknowledge that some of our language has referenced concepts

smaller than a national scope. For example, we have stated that “the shared

characteristic of the group should generally be recognizable by others in the

community . . . .” Matter of A-M-E- & J-G-U-, 24 I&N Dec. at 74. We also

have noted that “[p]ersecution limited to a remote region of a country may

invite an inquiry into a more limited subset of the country’s society, such as

in Matter of Kasinga, [21 I&N Dec. 357, 366 (BIA 1996)], where we

considered a particular social group within a tribe.” Matter of M-E-V-G-,

26 I&N Dec. at 243. The United States Court of Appeals for the Tenth

Circuit has stated that “social visibility requires that the relevant trait be

potentially identifiable by members of the community, either because it is

evident or because the information defining the characteristic is publically

accessible.” Rivera-Barrientos, 666 F.3d at 652. However, none of these

cases holds that a neighborhood or other limited geographic location within

a country constitutes a society for purposes of social distinction.

A proposed “social group must avoid, consistent with the evidence, being

too broad to have definable boundaries and too narrow to have larger

significance in society.” Matter of A-B- I, 27 I&N Dec. at 336. Focusing on

too narrow a subset of society runs the risk that the proposed group will lack

that larger significance to society. An alien can establish social distinction

through “[e]vidence such as country conditions reports, expert witness

testimony, and press accounts of discriminatory laws and policies, historical

animosities, and the like [that] may establish that a group exists and is

perceived as ‘distinct’ or ‘other’ in a particular society.” Matter of

M-E-V-G-, 26 I&N Dec. at 244. If a characteristic is recognizable to a

community, but is not necessarily recognizable beyond it, it is incumbent on

the applicant to cogently show how such a characteristic makes that group

socially distinct within the meaning of the INA.

The applicant’s proposed family social group falls within this

requirement. The family may have significance within the respective

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neighborhood in which the family resides or to the alleged persecutors.

However, there is insufficient evidence that this family carries greater

significance within Honduran society.

B. Nexus

We also reverse the Immigration Judge’s nexus determination. See

Matter of M-E-V-G-, 26 I&N Dec. at 242 (noting the importance of

distinguishing between the inquiry into whether a group is a “particular social

group” and whether a person is persecuted “on account of” membership in a

particular social group). Even if the immediate family here were determined

to constitute a valid social group, there is no nexus between it and the harm

asserted here. “An asylum applicant’s membership in a family-based

particular social group does not necessarily mean that any harm inflicted or

threatened by the persecutor is because of, or on account of, the family

membership.” Matter of L-E-A- I, 27 I&N Dec. at 43. “If the persecutor

would have treated the applicant the same if the protected characteristic of

the family did not exist, then the applicant has not established a claim on this

ground.” Id. at 43–44.

The Attorney General has adopted the test set forth in Matter of L-E-A- I

for determining nexus in cases of possible mixed motives. “To establish the

necessary nexus, the protected ground: (1) must be a but-for cause of the

wrongdoer’s act; and (2) must play more than a minor role—in other words,

it cannot be incidental or tangential to another reason for the act.” Matter of

A-B- II, 28 I&N Dec. at 208–09 (citing Matter of L-E-A- I, 27 I&N Dec. at

43–44).

The federal courts have generally been receptive to Matter of L-E-A- I’s

nexus analysis. For example, the Second Circuit has expressly quoted it.

Garcia-Aranda v. Garland, 53 F.4th 752, 757 (2d Cir. 2022). “[T]he fact

that a persecutor has threatened an applicant and members of his [or her]

family does not necessarily mean that the threats were motivated by family

ties.” Id. (alteration in original) (quoting Matter of L-E-A- I, 27 I&N Dec.

at 45). “Instead, because membership in the family cannot be a minor,

incidental, or tangential reason for the harm, ‘the fact that a persecutor targets

a family member simply as a means to an end is not, by itself, sufficient to

establish a claim, especially if the end is not connected to another protected

ground.’” Id. (quoting Matter of L-E-A- I, 27 I&N Dec. at 44–46). The court

further collected cases from other circuits adopting a substantially similar

standard. Id. at 757 n.4 (citing Thayalan v. Att’y Gen. of U.S., 997 F.3d 132,

142–44 (3d Cir. 2021); Orellana-Recinos v. Garland, 993 F.3d 851, 856–59

(10th Cir. 2021); Sanchez-Castro v. U.S. Att’y Gen., 998 F.3d 1281, 1286–88

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(11th Cir. 2021); Fuentes v. Barr, 969 F.3d 865, 871–72 (8th Cir. 2020)). 2

The Ninth Circuit has expressly adopted the test from Matter of A-B- II as

one way of establishing nexus, with the other being “whether the motive

arising from a protected ground was sufficient on its own to cause the harm.”

Manzano v. Garland, 104 F.4th 1202, 1207–09 (9th Cir. 2024).

However, the Fourth Circuit has not followed this approach. In the

context of analyzing a family-based social group claim, the Fourth Circuit

concluded that a mother’s relationship to her son was why she, and not

another person, was targeted. Hernandez-Avalos v. Lynch, 784 F.3d 944,

949–50 (4th Cir. 2015). Both the Attorney General and the Eleventh Circuit

have concluded that this analysis as inconsistent with the REAL ID Act’s

central reason test. See Matter of A-B- II, 28 I&N Dec. at 209 (“Even if the

protected characteristic is only used opportunistically, the Fourth Circuit

appears to believe that a causal relation is sufficient to establish nexus as a

matter of law.”); Sanchez-Castro, 998 F.3d at 1287 (“We decline to follow

this reasoning because it expands the nexus inquiry to include family status

as a central reason even when it is incidental and subordinate to another

reason for harm.” (citation modified)).

The Immigration Judge found that the gangs initially targeted the

applicant’s daughter for recruitment but then targeted the applicant because

she was the mother of that daughter. Under the framework of Matter of

L-E-A- I and Matter of A-B- II, this conclusion is incorrect. Even if the family

ties provide a “but-for” causation for harm to the applicant, the goals of

recruitment and sustaining the gang’s power and control are the only central

reasons for harm in this case.

We have stated that “nexus is not established simply because a particular

social group of family members exists and the family members experience

harm.” Matter of L-E-A- I, 27 I&N Dec. at 45. “This is why the Board

established a two-pronged test for proving nexus: the applicant’s protected

status must be both a but-for cause of her persecution and it must play more

than a minor role that is neither incidental nor tangential to another reason

2

While the Third Circuit generally adopts this standard, it does not accept our precedents

stating that a protected ground cannot be “subordinate” to another reason. Ndayshimiye v.

Att’y Gen. of U.S., 557 F.3d 124, 129–31 (3d Cir. 2009); cf. Matter of J-B-N- & S-M-,

24 I&N Dec. 208, 214 (BIA 2007) (stating that a protected ground “cannot be incidental,

tangential, superficial, or subordinate to another reason for harm”), aff’d sub nom.,

Ndayshimiye v. Att’y Gen. of U.S., 557 F.3d 124 (3d Cir. 2009).

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for the harm or a means to a non-protected end.” Matter of A-B- II, 28 I&N

Dec at 211.

The applicant’s expert testified “[a]nything that somehow undermines

[the gang’s] control is reason to be a target for harm.” Gangs utilize several

methods, including threats against others, to effect their interest in

developing their control. See, e.g., Matter of M-F-O-, 28 I&N Dec. 408, 412

(BIA 2021). The applicant’s claim that she was and will be persecuted on

account of membership in her immediate family as a central reason for the

harm she fears is undercut by the murder of the nephew who assisted her,

which reflects violence against more than immediate family members. This

tragic violence reflects that gangs target anyone or anything they see

providing a means to achieve compliance with their objectives, without

regard to a victim’s immediate family status.

The Immigration Judge cited Hernandez-Avalos, which arose in a

different circuit and, as noted, the Attorney General has stated is inconsistent

with the REAL ID Act’s central reason test. The Immigration Judge cited,

but did not give sufficient consideration to, the in-circuit Fifth Circuit case

of Ramirez-Mejia v. Lynch, 794 F.3d 485 (5th Cir. 2015). There, “the

evidence that gang members sought information from Ramirez-Mejia about

her brother, without more, [did] not support her claim that the gang intended

to persecute her on account of her family.” Ramirez-Mejia, 794 F.3d at 493.

The evidence of record is more akin to Ramirez-Mejia. As the expert

testified, the gangs target anyone who could be a threat to them, and the

applicant testified about gangs targeting a wide swath of people.

Indiscriminate harm has no nexus to a protected ground. The evidence does

not sufficiently establish that “the persecutors had any animus against the

family or the [applicant] based on their biological ties, historical status, or

other features unique to that family unit.” Matter of L-E-A- I, 27 I&N Dec.

at 47. Any family ties are not a central reason to the harm in this case.

III. CONCLUSION

Accordingly, the applicant is not eligible for statutory withholding of

removal, and we vacate the Immigration Judge’s grant of that relief from

removal. We need not reach DHS’ other arguments regarding that grant of

relief. See INS v. Bagamasbad, 429 U.S. 24, 25 (1976) (per curiam) (“As a

general rule courts and agencies are not required to make findings on issues

the decision of which is unnecessary to the results they reach.”). The

Immigration Judge did not reach the applicant’s claim for protection under

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the regulations implementing the Convention Against Torture, and we will

remand the record solely for that purpose. 3

ORDER: DHS’ appeal is sustained, and the Immigration Judge’s grant

of statutory withholding of removal is vacated.

FURTHER ORDER: The record is remanded to the Immigration Court

for further proceedings consistent with this decision and for the entry of a

new decision.

3

The Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or

Punishment, Dec. 10, 1984, S. Treaty Doc. No. 100-20, 1465 U.N.T.S. 85 (entered into

force for United States Nov. 20, 1994). 8 C.F.R. §§ 1208.16(c), 1208.17 (2026); 8 C.F.R.

§ 1208.18(a) (2020).

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