Legal Opinion

E-M-F-S

Board of Immigration Appeals

Decided January 9, 2026No. ID 4154PublishedCited by 1 opinion

1Opinion of the Court

Cite as

29 I&N Dec. 379

(BIA 2026) Interim Decision #4154 Matter of E-M-F-S-, et al., Respondents Decided January 9, 2026 U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals Death threats alone rarely rise to the level of persecution and only do so if they are objectively credible and issued by a person or persons with the immediate ability to carry them out. FOR THE RESPONDENT: Ernest Bradley, Esquire, Miami, Florida BEFORE: Board Panel: MALPHRUS, Chief Appellate Immigration Judge; VOLKERT, Appellate Immigration Judge; MCCLOSKEY, Temporary Appellate…

2Cases cited43 opinions

  1. Jian Hui Shao v. MukaseyCourt of Appeals for the Second Circuit · 2008
  2. ACOSTABoard of Immigration Appeals · 1985
  3. Melencio Legui Lim v. Immigration and Naturalization ServiceCourt of Appeals for the Ninth Circuit · 2000
  4. Immigration & Naturalization Service v. BagamasbadSupreme Court of the United States · 1976
  5. MOGARRABIBoard of Immigration Appeals · 1987

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3Cited by1 opinion

  1. V-S-ABoard of Immigration Appeals · 2026

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