The Ninth Circuit has amended its decision in Lkhasgvasuren v. Lynch.  Initially, the Court deferred to the Board of Immigration Appeals framework for whistleblower asylum cases, as articulated in Matter of N-M-.  In the amended decision, the Court assumed, without deciding, that the N-M- framework would apply to whistleblowing claims.

The amended decision in Lkhasgvasuren v. Lynch can be found here: 

http://cdn.ca9.uscourts.gov/datastore/opinions/2016/12/30/13-71778.pdf

Comment