Matter of H-

H- (plaintiff), a Somali member of the Marehan subclan (whose members had ruled the country until being ousted in 1990), fled after rival clans retaliated against his subclan: his father was murdered at his business, his brother was murdered at a hospital, and H- himself was detained and severely beaten before relatives helped him escape and fund his flight to the U.S., where he sought asylum. An immigration judge denied relief.

Whether a member of a clan effectively at war with other clans is eligible for asylum on the basis of persecution based on membership in a social group.