Matter of G-L-C-
29 I&N Dec. 717 (BIA 2026)
2026
Holding
(1) Conviction for possession with intent to deliver a controlled substance under Pennsylvania law is a particularly serious crime, barring both asylum and withholding. (2) Respondent did not establish CAT eligibility where past mistreatment in Jamaica based on sexual orientation was by private individuals and she did not show a public official would acquiesce to future torture.
Practitioner Note
Drug trafficking convictions are routinely found to be particularly serious crimes. CAT claims based on private actors require government acquiescence — general societal homophobia without state involvement is insufficient.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.