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2.0

AG Bondi issues Matter of R-E-R-M- & J-D-R-M-, narrowing family-based PSGs

  1. Original Date Announced

    September 2, 2025

    AG Bondi overrules AG Garland's decision in Matter of L-E-A-, 28 I&N Dec. 304 (A.G. 2021) and reinstates the legal standards defining "particular social group" from Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019).

    The Immigration and Nationality Act (“INA”) authorizes the Attorney General to grant asylum to individuals who meet several statutory requirements, including an inability to return to their home country because of “persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.” INA § 101(a)(42)(A), 8 U.S.C. § 1101(a)(42)(A). This decision holds that a family- or kinship-based group qualifies as a "particular social group" only if it is defined with sufficient particularity and is socially distinct in society. Bondi clarifies that "to be sufficiently particular, a group must have 'discernible boundaries' and cannot be 'too vague or amorphous.'" She also states that groups must be recognized by society at large, not just persecutors.

    Trump 2.0 [ID #1949]

    2025.09.02 Matter of R-E-R-M- & J-D-R-M-, 29 I&N Dec. 202 (A.G. 2025)
  2. Effective Date

    September 2, 2025

Current Status

None

Original Trump Policy Status

Status: Final/Actual
Trump Administration Action: Adjudication
Subject Matter: Asylum, Withholding and CAT
Agencies Affected: ICE AG EOIR USCIS

Associated or Derivative Policies

Pre Trump-Era Policies

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