Matter of P-A-C-
29 I&N Dec. 708 (BIA 2026)
2026
Holding
The fact that a respondent is granted withholding of removal is an important consideration in whether the respondent may be denied asylum as a matter of discretion based on weighing favorable and adverse factors. The mitigating impact a grant of withholding has on the risk of future persecution must be considered. Matter of Kasinga and Matter of H- distinguished.
Practitioner Note
An IJ who grants withholding must account for that protection when exercising discretion to deny asylum — the risk of persecution is reduced, which weighs in favor of asylum.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.