Matter of L-E-A-
27 I&N Dec. 40 (BIA 2017)
2017
Holding
Recognized that an applicant's nuclear family may constitute a particular social group where the family is targeted as a unit, but family-based PSGs must still satisfy particularity and social distinction.
Practitioner Note
A.G. narrowed nuclear family PSG in L-E-A-, 27 I&N Dec. 581 (A.G. 2019). A.G. Garland vacated in L-E-A-, 28 I&N Dec. 304 (A.G. 2021). The 2019 A.G. decision was reinstated by R-E-R-M-, 29 I&N Dec. 202 (A.G. 2025), holding nuclear family generally lacks social distinction.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.