M-Z-M-R
Citations
- 26 I. & N. Dec. 28
Syllabus
M-Z-M-R-, 26 I&N Dec. 28 (BIA 2012) ID 3769 (PDF) (1) In assessing an asylum applicant's ability to internally relocate, an Immigration Judge must determine whether the applicant could avoid future persecution by relocating to another part of the applicant's country of nationality and whether, under all the circumstances, it would be reasonable to expect the applicant to do so. (2) For an applicant to be able to internally relocate safely, there must be an area of the country where the circumstances are substantially better than those giving rise to a well-founded fear of persecution on the basis of the original claim. (3) If an applicant is able to internally relocate, an Immigration Judge should balance the factors identified at 8 C.F.R. § 1208.13(b)(3) (2012) in light of the applicable burden of proof to determine whether it would be reasonable under all the circumstances to expect the applicant to relocate.
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- requiring the 17 government to show there is an area for safe relocation, but 18 concluding burden can be met by showing that conditions 19 outside of the home region “were not such that the applicant 20 would have a well-founded fear”
- the proposed location “must present circumstances that are substantially better than those giving rise to a well-founded fear of persecution on the basis of the original claim” (emphasis added)
Source: CourtListener parenthetical corpus (CC0).
Cited by
10 cases in this archive cite this case.
- A-R-C-GBoard of Immigration Appeals· 2014-07-01· cited 121×
- Maria Juan Antonio v. William P. BarrSixth Circuit· 2020-05-19· cited 53×
- Shaker Ullah v. Merrick GarlandFourth Circuit· 2023-07-06· cited 26×
- Garcia-Cruz v. SessionsFirst Circuit· 2017-05-26· cited 22×
- Caz v. GarlandFirst Circuit· 2023-10-11· cited 13×
- Camara v. HolderFirst Circuit· 2013-07-26· cited 7×
- Urias-Orellana v. GarlandFirst Circuit· 2024-11-14· cited 7×
- Singh v. GarlandNinth Circuit· 2024-10-04· cited 6×
- Addo v. BarrTenth Circuit· 2020-12-14
- Shaker Ullah v. Merrick GarlandFourth Circuit· 2023-10-12
Cites
18 cases in this archive are cited by this case.
- Bernard Lukwago A/K/A Melvin Haft v. John Ashcroft, Attorney General of the United StatesThird Circuit· 2003-05-14· cited 474×
- MOGARRABIBoard of Immigration Appeals· 1987-07-01· cited 442×
- Arout Melkonian v. John Ashcroft, Attorney GeneralNinth Circuit· 2003-03-04· cited 368×
- Singh v. IlchertNinth Circuit· 1995-08-22· cited 232×
- Damjan Knezevic and Danica Knezevic v. John Ashcroft, Attorney GeneralNinth Circuit· 2004-05-24· cited 191×
- Afriyie v. HolderNinth Circuit· 2010-07-26· cited 127×
- Fahim Kaiser Faiza Fahim Sheryar Kaiser Anushay Fahim v. John Ashcroft, Attorney GeneralNinth Circuit· 2004-12-03· cited 124×
- HBoard of Immigration Appeals· 1996-07-01· cited 116×
- Denada M. Bace v. John Ashcroft, United States Attorney GeneralSeventh Circuit· 2003-12-18· cited 97×
- Singh v. IlchertNinth Circuit· 1995-11-01· cited 93×
- S-HBoard of Immigration Appeals· 2002-07-01· cited 72×
- Gambashidze v. AshcroftThird Circuit· 2004-08-26· cited 35×
- D-I-MBoard of Immigration Appeals· 2008-07-01· cited 29×
- Parussimova v. MukaseyNinth Circuit· 2008-07-24· cited 26×
- C-A-LBoard of Immigration Appeals· 1997-07-01· cited 23×
- RBoard of Immigration Appeals· 1992-07-01· cited 21×
- Manzoor v. United States Department of JusticeFirst Circuit· 2001-06-27· cited 20×
- Tendean v. GonzalesFirst Circuit· 2007-09-14· cited 15×
Sourced from CourtListener / Free Law Project (CC0).
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