The Seventh Circuit sustained an appeal of an applicant seeking withholding of removal based on her fear that she would be forced by her family to undergo female genital mutilation (FGM) if she returned to Botswana. The court noted that the family's two attempts to force the applicant to undergo FGM qualified as past persecution. Moreover, the fact that FGM is not widely practiced in Botswana did not undermine the applicant's fear of future harm, in light of her family's insistence that she undergo the procedure. Finally, the court challenged the Board of Immigration Appeals' (Board) determination that the applicant could safely relocate to another part of Botswana, noting that the Department of Homeland Security had not raised this issue on appeal to the Board, the Immigration Judge had not addressed the issue in his decision, and the Board has limited fact-finding capability.
The full text of Musa v. Lynch can be found here: http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2016/D02-19/C:15-2046:J:Hamilton:aut:T:fnOp:N:1706751:S:0