Matter of H-

Board of Immigration Appeals

21 I & N Dec. 337 (B.I.A. 1996)

For asylum purposes, a member of a clan being attacked by other clans is considered to be persecuted based on a social group.

Relevant Facts

H- (the plaintiff) is a Somalian member of the Darood clan and the Marehan subclan. A member of the Marehan subclan ruled Somalia for 21 years until 1990, when he was ousted from power by other clans. Subsequently, the other clans retaliated against members of the Marehan subclan who were favored in the previous regime. The plaintiff’s father was murdered in his business by another clan, and his brother was murdered at a hospital after the family home was attacked. The plaintiff fled to another town but was detained by an armed group as was severely beaten. A relative in the group helped him escape and another provided him funds to flee to the United States, where he sought asylum. The plaintiff appealed.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 12, 2020

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Procedural History

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Citations

21 I & N Dec. 337 (B.I.A. 1996)