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Original Date Announced
September 2, 2025AG 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)Effective Date
September 2, 2025Current Status
NoneOriginal Trump Policy Status
Status: Final/ActualTrump Administration Action: AdjudicationSubject Matter: Asylum, Withholding and CATAssociated or Derivative Policies
- July 29, 2019 AG decides Matter of L-E-A-, narrowing family-based PSGs
Pre Trump-Era Policies
- June 16, 2021 Matter of L-E-A-, 28 I&N Dec. 304 (A.G. 2021)
Documents
Trump-Era Policy Documents
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New Policy
Original Source:
Matter of R-E-R-M- & J-D-R-M-, 29 I&N Dec. 202 (A.G. 2025)
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Prior Policy
Original Source:
Matter of L-E-A-, 28 I&N Dec. 304 (A.G. 2021)
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