Government Persecution & Protection

268 F.3d 1143 (9th Cir. 2001) · 2001

Government cannot avoid asylum obligations by pointing to internal relocation where relocation would be unreasonable or where persecution is carried out by the government itself or with government complicity.

29 I&N Dec. 307 (BIA 2025) · 2025

A single attempt to report an incident of harm by private actors to local police, without further harm from the police themselves or evidence of widespread collusion with alleged persecutors, does not establish that the government as a whole is unable or unwilling to protect a respondent from persecution.

One police report, standing alone, is insufficient to prove government protection failure. Applicants must demonstrate systemic inability or unwillingness, not a single episode.