In Pan v. Holder, the Second Circuit overturned the BIA's determination that the petitioner had not suffered harm severe enough to constitute persecution.  In so doing, the court noted that Pan had suffered three beatings over the course of four years, and that the last of these beatings required a two-week hospitalization.  Moreover, the court took issue with the Immigration Judge's finding that these events, at best, constituted "hate crimes," finding that while not all hate crimes may qualify as persecution, a severe enough hate crime certainly could qualify as persecution.

The full text of Pan v. Holder can be found here: