Matter of K-S-H-
29 I&N Dec. 307 (BIA 2025)
2025
Holding
A single attempt to report an incident of harm by private actors to local police, without further harm from the police themselves or evidence of widespread collusion with alleged persecutors, does not establish that the government as a whole is unable or unwilling to protect a respondent from persecution.
Practitioner Note
One police report, standing alone, is insufficient to prove government protection failure. Applicants must demonstrate systemic inability or unwillingness, not a single episode.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.