The Ninth Circuit has determined that a petitioner who was prohibited from attending his house church suffered past persecution.  "By forbidding Petitioner from attending his home church, the Chinese police prevented him from practicing his faith and did so through coercive means. The harm Petitioner suffered was therefore ongoing and, under our asylum precedent, compelled a finding of past persecution."  Specifically, the Court noted that "the police here actively ensured that Petitioner could not practice his faith, forcing him and fellow congregants to report to the police station weekly and threatening him with arrest for noncompliance."

The full text of Guo v. Sessions can be found here: