Matter of Chang
Board of Immigration Appeals
20 I & N Dec. 38 (1989)
Chang (defendant), a Chinese national, fled to the United States after he and his wife were ordered to undergo sterilization following the birth of their second child, though neither had ever been mistreated by Chinese authorities; his asylum application cited Communist domination generally rather than opposition to China's population-control policies specifically, since he didn't understand English well enough to know he should mention it. The immigration judge denied asylum and withholding of deportation and found him removable, and Chang appealed.
Whether a fear of mandatory sterilization shows that an alien has been persecuted or has a well-founded fear of persecution as required for asylum.