Internal Relocation

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. 456 (BIA 2026) · 2026

(1) Unique barriers to reporting harm faced by children do not apply to adults, including adults who suffered harm as children. (2) Given Russia's size, respondent's membership in the majority religion, and insufficient evidence that her family maintains interest in locating her more than 2 years after threats, the IJ's finding that the respondent could not reasonably relocate was clearly erroneous.

Internal relocation analysis in Russia must account for the country's geographic size. Adult applicants cannot rely on childhood reporting barriers; the reasonableness of relocation is assessed on adult facts.