Matter of V-A-B-
BIA
29 I&N Dec. 621 (BIA 2026)
2026
Holding
(1) The proposed PSG 'married Mexican women who are unable to leave their relationship' is not cognizable because it is circularly defined and lacks particularity. (2) The existence of a lawful marriage cannot be presumed simply because two persons are cohabitating or have children in common.
Practitioner Note
Post-S-S-F-M- decision further narrowing domestic violence PSG formulations. Circular definitions — where the harm defines the group — remain per se non-cognizable.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.