Persecutor Bar
Cases — Persecutor Bar
Matter of Negusie (A.G.)
BIAA.G.
29 I&N Dec. 285 (A.G. 2025) · 2025
The stay of the Board's prior order is vacated. Matter of Negusie, 28 I&N Dec. 120 (A.G. 2020) — holding that the persecutor bar contains no duress exception — is now the operative opinion.
Reinstates the no-duress-exception rule for the persecutor bar following years of litigation. There is no escape hatch for individuals who assisted in persecution under compulsion.
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