Matter of A-C-M-
Board of Immigration Appeals
27 I. & N. Dec. 303 (2018)
A-C-M- (plaintiff), a Salvadoran national who entered the United States without inspection in 1991, had earlier been kidnapped by Salvadoran guerillas and forced, under threat of death, to cook and clean for them; an immigration judge in 2016 found her ineligible for asylum under the material-support bar, and she appealed, arguing her assistance was de minimis and not material, and that even if the bar applied, she deserved a duress exception.
Whether, under Section 212(a) of the Immigration and Nationality Act, an alien provides material support to a terrorist organization if the act has a logical and reasonably foreseeable tendency to promote or maintain the organization, even if only to a de minimis degree and performed under duress.