Matter of A-R-C-G-
BIA
26 I&N Dec. 388 (BIA 2014)
2014
Holding
Recognized 'married women in Guatemala who are unable to leave their relationship' as a cognizable PSG under certain factual circumstances, opening a pathway for domestic violence asylum claims.
Practitioner Note
Landmark domestic violence decision. Overruled by A-B- 2018 (A.G. Sessions). Restored by A-B- 2021 (A.G. Garland). Overruled again by Matter of S-S-F-M-, 29 I&N Dec. 207 (A.G. 2025), which reinstated A-B- 2018 as controlling law.
This summary describes what the tribunal held. Always verify the citation and read the full decision before relying on it. Case law changes — confirm this decision has not been overruled, limited, or superseded. Not legal advice.