Hounmenou, et al v. Holder, Jr., No. 11-1990 (8th Cir. 2012)
Annotate this CasePetitioners petitioned for review of the BIA's decision affirming the IJ's denial of their application for asylum, withholding of removal, and protection under the Convention Against Torture. Petitioner Mathias belongs to the Fom ethnic group and his extended family practices the Vodun religion (colloquially known as "voodoo"). Petitioners contended that the BIA erred by analyzing Mathias's fear of persecution based on the potential female genital mutilation (FGM) of his daughter as a derivative claim, instead of as a claim of direct persecution of Mathias. The court denied the petition for review, concluding that the decisions of the IJ and BIA were supported by substantial evidence and that this was not a case where the BIA might reach a different conclusion after a more complete evaluation of the record. The IJ and BIA noted, among other things, that the daughter did not face a well-founded fear of persecution in the form of FGM.
Court Description: Petition for Review - Immigration. Assuming, without deciding, that petitioner was entitled to raise a claim of direct persecution based on the threat of female genital mutilation to his daughter, such a claim would necessarily fail because the Immigration Judge expressly found that the daughter herself did not have a well-founded fear of being subjected to the FGM.
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