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Matter of S-K-

Board of Immigration Appeals
23 I & N Dec. 936 (2006)


S-K- (plaintiff) is a native citizen of Burma. She is a Christian and a member of the ethnic Chin minority. The military junta ruling Burma has a history of abusing ethnic and religious minorities, and killed S-K-‘s fiancé. In 2001, S-K- began monetarily supporting the Chin National Front (CNF), an organization dedicated to the freedom of the ethnic Chin people in Burma. She donated money for 11 months and also attempted to donate other small goods. While she was in Singapore on a temporary visa, an agent for the CNF advised S-K- to flee Burma because the military had learned of her support of the CNF. She fled to the United States to seek asylum. The Immigration Judge found that while she otherwise qualified for asylum, he denied her application because she materially supported an organization that uses firearms and explosives to endanger the safety of others or cause substantial property damage. She then appealed to the Board of Immigration Appeals.

Rule of Law


Holding and Reasoning (Pauley, J)

Concurrence (Osuna, J)

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