Matter of S-E-G-
Board of Immigration Appeals
24 I & N Dec. 579 (2008)
A 19-year-old Salvadoran woman and her two 16-year-old brothers (petitioners) fled El Salvador after MS-13 gang members harassed and beat the brothers for refusing recruitment and threatened the sister, in a neighborhood where MS-13 had previously killed a boy for similarly refusing to join. The immigration judge found their testimony credible but concluded the beatings and threats were recruitment efforts rather than persecution based on membership in a particular social group, denying asylum and other relief; they appealed to the Board.
Whether, under § 101(a)(42) of the Immigration and Nationality Act, membership in a particular social group requires that the group have particular and well-defined boundaries and possess a level of social visibility.