
The BIA’s Reaffirmation of the Specific-Intent Requirement for CAT Deferral: Tracing the Doctrinal Line from Matter of J-E- (2002) Through the 2025–2026 Precedents on Detention, Mental Health, and Expert Testimony
Article 3 of the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (“CAT”) imposes a non-derogable obligation on States Parties: no signatory may return a person to a country where that person faces a substantial risk of torture.


