Matter of F-B-A-
29 I&N Dec. 456 (BIA 2026)
2026
Holding
(1) Unique barriers to reporting harm faced by children do not apply to adults, including adults who suffered harm as children. (2) Given Russia's size, respondent's membership in the majority religion, and insufficient evidence that her family maintains interest in locating her more than 2 years after threats, the IJ's finding that the respondent could not reasonably relocate was clearly erroneous.
Practitioner Note
Internal relocation analysis in Russia must account for the country's geographic size. Adult applicants cannot rely on childhood reporting barriers; the reasonableness of relocation is assessed on adult facts.
Topics
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.