Nexus — On Account Of

21 I&N Dec. 486 (BIA 1996) · 1996

In mixed-motive cases, persecution is 'on account of' a protected ground if the protected characteristic is at least one central reason for the persecution.

27 I&N Dec. 316 (A.G. 2018) · 2018

Held that claims by aliens who suffer domestic violence or gang violence generally will not qualify for asylum; overruled Matter of A-R-C-G- and raised significant barriers to domestic violence and gang-based PSG claims.

Issued by A.G. Sessions. Vacated by A.G. Garland in A-B-, 28 I&N Dec. 307 (A.G. 2021). Reinstated as controlling law by Matter of S-S-F-M-, 29 I&N Dec. 207 (A.G. 2025).

384 F.3d 743 (9th Cir. 2004) · 2004

Reversed denial of asylum where applicant, a Senegalese journalist, faced threats; government's desire to silence him reflected imputation of a political opinion regardless of whether he personally held that opinion.

622 F.3d 1007 (9th Cir. 2010) · 2010

An alien's desire to be free from harassment by criminals motivated by theft or personal malice does not implicate a protected ground; gang violence motivated by personal animus or desire for criminal profit does not establish nexus.

Frequently cited for the proposition that criminal motivation breaks the nexus to a protected ground.

846 F.3d 351 (9th Cir. 2017) · 2017

The 9th Circuit applies an 'a reason' nexus standard (not 'a central reason') to withholding of removal claims; the two standards differ, and courts must apply the appropriate one for each form of relief.

Critical for practitioners: asylum requires 'a central reason'; withholding of removal requires only 'a reason.' This distinction can affect strategy.

320 F.3d 1061 (9th Cir. 2003) · 2003

In mixed-motive cases, asylum is warranted if persecution occurred at least in part because of a protected ground; the protected characteristic need not be the sole or even primary motivation.

29 I&N Dec. 739 (BIA 2026) · 2026

(1) Conscription does not serve as a standalone basis for asylum absent a nexus to a protected ground. (2) Conscription requiring an alien to engage in internationally condemned inhuman conduct constitutes persecution only when tethered to a protected ground. (3) International condemnation of Russian military actions is insufficient; the respondent must show he himself would necessarily be required to engage in inhuman conduct on account of a protected ground.

Directly addresses Russian military conscription claims. Conscientious objection to military service requires nexus to political opinion or another protected ground — generalized objection to war crimes is not enough.