CLINIC co-authored an amicus brief in Scarlett v. Barr, a precedential decision from the Court of Appeals for the Second Circuit upholding Matter of A-B-’s interpretation that governments must “condone” or be “completely helpless” in controlling private actor harm. The amicus brief argues that the Court heightened the standard and that the decision will have a devastating impact on pro se applicants. 

Update: Unfortunately, on July 10, 2020, the Second Circuit denied the petition for rehearing.