
From Child-Sensitive Protection to Adult-Reporting Expectations. Matter of F-B-A- and the Recalibration of the “Unable or Unwilling” Inquiry in U.S. Asylum Law
In Matter of F-B-A-, 29 I. & N. Dec. 456 (B.I.A. 2026), the Board of Immigration Appeals held that the “unique barriers” children face in reporting abuse to authorities do not extend to adults—even adults describing childhood harm—when adjudicators assess whether the state is “unable or unwilling” to protect against private-actor persecution.



