CA4 on Social Group, Former (MS-13) Gang Membership: Martinez v. Holder

"[W]e conclude that the BIA erred as a matter of law in its interpretation of the phrase “particular social group” by holding that former gang membership is not an immutable characteristic of a particular social group for purposes of § 1231(b)(3)." - Martinez v. Holder, Jan. 23, 2014.  [Hats off to Maureen Sweeney, Benjamin Richard Casper, Alison D. Yoder, Andres C. Benach, Katherine Evans, Samuel Johnson and Holden Turner!]