Matter of R-E-R-M- & J-D-R-M- (A.G.)
29 I&N Dec. 202 (A.G. 2025)
2025
Holding
Matter of L-E-A-, 28 I&N Dec. 304 (A.G. 2021) is overruled. IJs and the Board should adhere to Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019), which held that nuclear family members generally do not constitute a cognizable PSG because nuclear families, as defined by the biological or legal relationship between an alien and family members, lack the requisite social distinction in most societies.
Practitioner Note
Reinstates the narrow 2019 A.G. framework for family-based PSG claims. Nuclear family alone generally insufficient without independent 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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.