Matter of E-A-G-

BIA

24 I&N Dec. 591 (BIA 2008)

2008

Holding

Persons resistant to gang recruitment in El Salvador and young men in El Salvador do not constitute cognizable PSGs due to lack of social visibility and particularity.

Practitioner Note

Companion to Matter of S-E-G-. Together these cases established the social visibility and particularity requirements.

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