Matter of Negusie (A.G.)
BIAA.G. Decision
29 I&N Dec. 285 (A.G. 2025)
2025
Holding
The stay of the Board's prior order is vacated. Matter of Negusie, 28 I&N Dec. 120 (A.G. 2020) — holding that the persecutor bar contains no duress exception — is now the operative opinion.
Practitioner Note
Reinstates the no-duress-exception rule for the persecutor bar following years of litigation. There is no escape hatch for individuals who assisted in persecution under compulsion.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.