Asylum law was enacted in the United States as a social policy to assist and protect deserving international refugees. In a recent decision, Matter of A-R-C-G-, the Board of Immigration Appeals acknowledged for the first time in a precedential decision that at least some domestic violence victims are eligible for asylum relief through "particular social group" constructions. The Board held that "married women in Guatemala who are unable to leave their relationships" constitute a "particular social group" within the meaning of the Immigration and Nationality Act. Through this decision, the Board recognized a narrowly defined social group claim brought by a domestic violence victim. However, the precedential value of Matter ofA-R-C-G- causes confusion in its practical application, as the boundaries for a cognizable social group relating to domestic violence are not defined in the decision.

This Comment first explores the evolving legislative and administrative history of "particular social group" requirements within asylum law, specifically with respect to domestic violence-related claims. In addition, this Comment explores the various interpretations of Matter of A-R-C-G-'s precedential value. This Comment then evaluates the adequacy of alternative forms of immigration relief for domestic violence victims already present within the United States. Finally, this Comment will recommend that adjudicators should broadly interpret Matter ofA-R-C-G-'s precedential value when analyzing future domestic violence-related social group claims to include victims of various nationalities, genders, marital statuses, and similar domestic abuse situations.



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