N-A-M v. Holder

Petitioner N-A-M seeks review of a Board of Immigration Appeals’ (“BIA”) decision to remove her to her native El Salvador.1 Although the Immigration Judge determined that N-A-M had a “viable persecution claim,” I.J. Dec. at 8, the Immigration Judge denied, and the BIA affirmed, her petition for withholding of removal because she had been convicted of felony menacing — a “particularly serious crime,” pursuant to the Refugee Act of 1980, Pub.L. 96-202, 94 Stat. 102, see 8 U.S.C. § 1231.

On appeal, N-A-M asserts three legal errors in the BIA’s decision: First, she argues that felony menacing does…