National Immigrant Justice Center
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AREVALO-GIRON V. HOLDER
1st Circuit
Arevalo-Giron v. Holder (1st Circuit, January 31, 2012)
SELYA, Lynch, Torruella
Summary: The First Circuit affirmed the agency’s denial of El Salvadoran petitioner’s application for asylum, finding that he failed to establish that his past persecution at the hands of FMLN guerrillas—which included carrying severely wounded guerrillas, conscription to detonate bombs and ambush government soldiers, forced attendance at political rallies, and forced labor—was on account of his political opinion.
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