Board of Immigration Appeals· 7/1/2008

S-A-K- and H-A-H

Citations

24 I. & N. Dec. 464

Syllabus

S-A-K- and H-A-H-, 24 I&N Dec. 464 (BIA 2008) ID 3602 (PDF) A mother and daughter from Somalia who provided sufficient evidence of past persecution in the form of female genital mutilation with aggravated circumstances are eligible for a grant of asylum based on humanitarian grounds pursuant to 8 C.F.R § 1208.13(b)(1)(iii)(A) (2007), regardless of whether they can establish a well-founded fear of future persecution. Matter of Chen, 20 I&N Dec. 16 (BIA 1989), followed.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

holding that applicants subject to past FGM with aggravated circumstances are eligible for a grant of asylum based on humanitarian grounds regardless of whether they can establish a well-founded fear of persecution
stating that female genital mutilation is a \continuing harm\ that \has ongoing physical and emotional effects\
\[T]he fact that FGM is generally performed only once ... eliminat[es] the risk of identical future persecution.\
“[T]he fact that FGM is generally performed only once ... eliminat[es] the risk of identical future persecution.”

Source: CourtListener parenthetical corpus (CC0).

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