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.