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Document: Forced Labor Constitutes Material Support, Board of Immigration Appeals Finds

Quinta Jurecic
Sunday, June 10, 2018, 1:52 PM

In a June 6th ruling, the Board of Immigration Appeals dismissed and remanded the case of a woman appealing an immigration judge's decision to deny her asylum application because of her provision of material support to guerillas in El Salvador. The woman was kidnapped by the guerillas and forced to cook and clean for them, as well as to undergo weapons training. The guerrillas also forced her to watch as her husband dug his own grave before being murdered.

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In a June 6th ruling, the Board of Immigration Appeals dismissed and remanded the case of a woman appealing an immigration judge's decision to deny her asylum application because of her provision of material support to guerillas in El Salvador. The woman was kidnapped by the guerillas and forced to cook and clean for them, as well as to undergo weapons training. The guerrillas also forced her to watch as her husband dug his own grave before being murdered. The Board of Immigration Appeals found that the woman's actions nevertheless constituted material support under the Immigration and Nationality Act and that the immigration court was therefore correct that she was ineligible for asylum.

The decision is available here and in full below.


Quinta Jurecic is a fellow in Governance Studies at the Brookings Institution and a senior editor at Lawfare. She previously served as Lawfare's managing editor and as an editorial writer for the Washington Post.

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