The BIA held that even in the Third Circuit, an untimely asylum application can be found to be a frivolous asylum application if misrepresentation was made regarding timeliness.
The BIA issued an amicus invitation to ask for briefs answering the question of whether there is a duress exception to the persecutor bar to asylum and withholding of removal.
In the Matter of J.M. Alvarado, the Board held that an alien’s personal motivation is irrelevant to the question of whether the persecutor bar applies.
In Matter of X-Q-L-, the BIA clarified the standard for granting a DHS motion to reopen to terminate asylum based on asylum fraud.
USCIS Acting Director Cuccinelli issued guidance to asylum offices on considering internal relocation in asylum credible fear interviews based on private violence.
In Matter of L-E-A-, Attorney General William Barr restricted the application of the particular social group ground for asylum to groups based on family.
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