H-M

Citations

• 20 I. & N. Dec. 683

Syllabus

H-M-, 20 I&N Dec. 683 (BIA 1993) ID 3204 (PDF) (1) Comparing Acewiczv. United States INS, 984 F.2d 1056 (9th Cir. 1993), with Castillo-Villagrav. INS, 972 F.2d 1017 (9th Cir. 1992), the Board concluded that it maytake administrative notice of the change in conditions of a country inthose cases arising within the jurisdiction of the United States Courtof Appeals for the Ninth Circuit when an alien acknowledges this Board'sauthority to do so and discusses the changed circumstances on appeal. (2) Where an asylum applicantfocuses his application on past persecution, the requirement to show thatthere is little likelihood of future persecution can be satisfied by takingadministrative notice of the change in circumstances in the country atissue. (3) Where an asylum applicantviolates currency laws which a government has a legitimate right to enforce,and he suffers harsh treatment as a result, the applicant must show thatthe government in question has punished him \on account of\his political opinion and not for the violation of the currency laws.INS v. Elias-Zacarias, 502 U.S. 478 (1992), followed.