Matter of D-G-B-L-
BIA
29 I&N Dec. 392 (BIA 2026)
2026
Holding
The serious nonpolitical crime bar to asylum and withholding of removal does not include a duress exception.
Practitioner Note
Companion in principle to Negusie (persecutor bar). Neither the particularly serious crime bar nor the serious nonpolitical crime bar yields to claims of duress or compulsion.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.