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Matter of H-

Board of Immigration Appeals
21 I & N Dec. 337 (1996)


H- (plaintiff) is a Somalian member of the Darood clan and the Marehan subclan. A member of the Marehan subclan ruled Somalia for 21 years until 1990, when he was ousted from power by other clans. As a result, the other clans retaliated against members of the Marehan subclan who were favored in the previous regime. H-'s father was murdered in his business by another clan, and his brother was murdered at a hospital after the family home was attacked. H- fled to another town but was detained by an armed group who severely beat him. A relative in the group helped him escape and another provided him funds to flee to the United States where he sought asylum. This appeal followed.

Rule of Law


Holding and Reasoning (Rosenberg, J.)

Dissent (Heilman, J.)

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