CARVALHO-FROIS V. HOLDER

1st Circuit 

Carvalho-Frois v. Holder (1st Circuit January 26, 2012)
SELYA, Howard, Boudin

Summary: The First Circuit affirmed the agency’s denial of asylum to the Brazilian petitioner. The petitioner had witnessed a murder in her neighborhood in Brazil and was threatened a couple of times by one of the assailants not to go to the police or they would kill her. She never went to the police because she viewed them as corrupt. In jumbling the elements of a claim to asylum, the First Circuit found that the petitioner’s claim did not qualify as past persecution or the fear of future persecution because the petitioner’s proposed social group lacked social visibility.

Read the opinion here.