Matter of S-E-M-Z-
BIA
29 I&N Dec. 680 (BIA 2026)
2026
Holding
The 'social distinction' element of a particular social group must generally be measured on a countrywide basis, rather than from the perspective of a neighborhood or other limited geographic location within a country.
Practitioner Note
Forecloses a common litigation strategy of showing local social recognition of a group. Social distinction must be assessed nationally, not merely in the applicant's home community.
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