Practice Pointer: Matter of L-E-A-

Last Updated

April 20, 2020

On July 29, 2019, the attorney general issued a decision, Matter of L-E-A-, 27 I&N Dec. 581 (A.G. 2019), overturning the part of the 2017 Board of Immigration Appeals decision in this case discussing whether Mr. L-E-A-’s proposed particular social group is cognizable. While the attorney general’s decision uses sweeping language about family-based particular social groups, the holding essentially states that each claim must be analyzed on a case-by-case basis. This practice pointer summarizes the decision and gives practitioners tips on how to represent asylum-seekers with family-based claims going forward. In additition to the practice pointer, CLINIC has translated Title II of the Salvadoran Civil Code entitled “Rules Relative to Intestate Succession,” which may help practitioners establish a cognizable family-based particular social group on behalf of Salvadoran clients.

Since the attorney general decided Matter of L-E-A II, CLINIC joined as co-counsel to Mr. L-E-A- and is monitoring how government officials and immigration judges are interpreting the attorney general’s opinion. To that end, please share with CLINIC redacted copies of any decisions that rely on the attorney general’s opinion by contacting Bradley Jenkins at