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Legal Opinion

H-L-S-M

Board of Immigration Appeals

Decided June 18, 2026No. ID 4220Published

1Opinion of the Court

Cite as

29 I&N Dec. 767

(BIA 2026) Interim Decision #4220 Matter of H-L-S-M-, Applicant Decided by Board June 18, 2026 1 U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals (1) The Immigration Judge clearly erred in finding it more likely than not the applicant will be tortured if removed to either Mexico or Guatemala based on general country conditions evidence and expert witness testimony about corruption while overlooking key facts regarding the applicant’s individualized circumstances, including lack of past torture, the passage of time since the…

2Cases cited7 opinions

  1. Shpetim Hoxha v. John Ashcroft, Attorney GeneralCourt of Appeals for the Ninth Circuit · 2003
  2. Ukashu Nuru, AKA Ukasha Nuru v. Alberto R. Gonzales, Attorney GeneralCourt of Appeals for the Ninth Circuit · 2005
  3. Abdifatah Gaas Qorane v. William Barr, U. S. AttyCourt of Appeals for the Fifth Circuit · 2019
  4. O-A-R-GBoard of Immigration Appeals · 2025
  5. Kwang Park v. Merrick GarlandCourt of Appeals for the Ninth Circuit · 2023

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