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BIA holds “Mexican children who are perceived as property and lack effective familial protection” as a cognizable particular social group in unpublished decision

In April 28, 2017 unpublished decision:

However, the Immigration Judge rejected as invalid the respondent’s proposed particular social

group of”Mexican children who are perceived as property and lack effective familial protection,”

finding that it lacked the requisite immutability, particularity, and social distinction (I.J. at 7-9).

The question whether a group is a “particular social group” within the meaning of the Act is a

question of law that we review de novo. Matter of A-R-C-G-, supra, at 390. On review, we find

that the particular social group posited by the respondent, under the circumstances of this case, is

valid under the reasoning of our recent decisions clarifying the approach to particular social

groups. See Matter of M-E-V-G-, 26 I&N Dec. 227 (BIA 2014); Matter of W-G-R-, 26 I&N

Dec. 208 (BIA 2014)

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