Matter of M-E-V-G
Board of Immigration Appeals
26 I. & N. Dec. 227 (2014)
MEVG (petitioner), a Honduran native, sought asylum claiming persecution by a gang because he belonged to a youth group refusing to join gangs; an immigration judge denied his application, the Board affirmed, and the Third Circuit granted review and remanded for further consideration of his particular-social-group argument, finding the Board hadn't adequately explained its 'particularity' and 'social visibility' requirements while leaving room for the Board to refine that definition on remand.
Whether, in interpreting 'particular social group' under the Immigration and Nationality Act, the requirement that the group have social visibility means the group must have literal, ocular visibility.