Matter of L-A-L-T-
BIA
29 I&N Dec. 269 (BIA 2025)
2025
Holding
(1) Perceived or imputed PSG membership only satisfies the PSG requirements if the underlying group of which the respondent is perceived to be a member is, standing alone, sufficiently cognizable. (2) 'Perceived Salvadoran gang members' is not a cognizable PSG. Matter of E-A-G-, 24 I&N Dec. 591 (BIA 2008), reaffirmed.
Practitioner Note
Closes the 'perceived membership' workaround — the underlying group must itself be cognizable, not merely the perception.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.