Matter of S-S-F-M- (A.G.)

BIAA.G. Decision

29 I&N Dec. 207 (A.G. 2025)

2025

Holding

Matter of A-B-, 28 I&N Dec. 307 (A.G. 2021) is overruled. IJs and the Board shall adhere to Matter of A-B-, 27 I&N Dec. 316 (A.G. 2018). By extension, Matter of A-R-C-G-, 26 I&N Dec. 388 (BIA 2014), and any decision issued in reliance thereupon, is also overruled.

Practitioner Note

Landmark 2025 A.G. decision reinstating the A-B- 2018 restrictions on domestic violence and gang-based claims and overruling A-R-C-G-. Current controlling framework for these claims.

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