Matter of L-A-D-
29 I&N Dec. 634 (BIA 2026)
2026
Holding
(1) 'Mexican men with Schizoaffective Disorder,' defined only by such diagnosis, is not cognizable as a PSG. (2) A series of speculative occurrences that also lack evidence of persecutory intent is insufficient to demonstrate a well-founded fear of persecution.
Practitioner Note
Mental health diagnoses, standing alone, do not define a cognizable PSG. A group must have social distinction — not merely a shared medical condition — and must be socially recognized as a distinct group in the relevant society.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.