A Proposal for Defining a Core Zone of Protection Under Membership in a Particular Social Group: Refocusing the Analysis to Utilize Both the Social Visibility Component and the Group Immutability Comp


This Comment suggests an alternative approach to analyzing new and novel

claims for membership in a particular social group by calling for defining a core area of

protection that can be supported and delineated within the current refugee definition. The

current approach in adjudicating any social group claims derives from seminal decision

by the Board of Immigration Appeals in Matter of Acosta.9 This approach is essentially a

line drawing attempt to create an outermost limit as to which claims establish a social

group for the purposes of refugee protection. This approach only looks at one side of the

coin, it looks only to the inherently internal component of any social group claim, the


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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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