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Original Date Announced
September 2, 2025Attorney General Pamela Bondi overruled the Matter of A-B- III, a 2021 decision issued by Attorney General Merrick Garland, and reinstated the legal standards from Matter of A-B- I and Matter of A-B- II that were issued by Attorney General Jeff Sessions and Attorney General Jeffrey Rosen, respectively. The new decision also effectively overruled Matter of A-C-R-G-, 26 I&N Dec. 388 (BIA 2014), and its progeny. The legal standard now applicable largely rejects domestic violence as grounds for asylum.
Bondi indicated this decision was influenced by the fact that "there may be circumstances when a government's failure to control private conduct itself amounts to persecution, [but it is] entirely correct to treat those circumstances as few and far between."
Trump 2.0 [ID #1948]
2025.09.02 AG Decision - Matter of S-S-F-M-Effective Date
September 2, 2025Current Status
NoneOriginal Trump Policy Status
Status: Final/ActualTrump Administration Action: AdjudicationSubject Matter: Hearings and Adjudications Asylum, Withholding and CATAssociated or Derivative Policies
Pre Trump-Era Policies
- June 16, 2021 Matter of A-B-, 28 I&N Dec. 307 (A.G. 2021)
Documents
Trump-Era Policy Documents
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New Policy
Original Source:
2025.09.02 AG Decision - Matter of S-S-F-M-
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Prior Policy
Original Source:
Matter of A-B- 28 I&N Dec. 307 (A.G. 2021)
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Commentary
2025.09.16 Attorney General Reinstates Harmful Decision on Domestic Violence Asylum - Tahirih Justice Center
Tahirih Justice Center comments that Matter of S-S-F-M- means that asylum claims will be harder to prove for survivors of gender-based violence and that survivors may be deterred from even seeking asylum. The decision also returns to an out-of-date view of domestic violence as a “private matter” instead of persecution rooted in systemic inequalities.
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