Asylum Granted by Cleveland IJ: Guatemalan Women Unable to Leave Common-Law Marriage

"Respondent has established that Guatemalan women who are unable to leave a common law relationship is a particular social group. ... Considering these actions in context with the fact that most such violence in Guatemala is motivated by gender, the Court finds that the Respondent has demonstrated that her being a Guatemalan woman who is unable to leave her common law relationship is at least one central reason for Mr. Z's actions against her. ... The evidence demonstrates that Guatemala is unable or unwilling to protect the Respondent from Mr. Z. Thus, the Court finds that the Respondent has established that she has suffered past persecution at the hands of an actor that the government of Guatemala is unable or unwilling to control because seeking government protection would be futile. Therefore, the Respondent is entitled to the rebuttable presumption that she has a well-founded fear of future persecution ... conditions render relocation within Guatemala unreasonable for the Respondent." - Matter of X-, Feb. 24, 2014.  [Hats off to Jennifer Peyton!]