In another depressing episode in the saga of gang-related asylum cases, the Eighth Circuit today determined that victims of gang violence, and those who refuse to join gangs, are not members of particular social groups.  The court noted that this group lacks visibility and particularity.  Though the petitioner tried to argue that he would also be persecuted on account of his Mam ethnicity, the court determined that it had no jurisdiction over this claim which had not been administratively exhausted.


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