The First Circuit has rejected the particular social group of “single mothers who are living without male protection and cannot relocate elsewhere in the country.” "The amorphous nature of Petitioner's sprawling group precludes determinacy and renders the group insufficiently particular. Her proffered social group is overly broad and potentially encompasses all single mothers in El Salvador who may find themselves unable to relocate in the country. Moreover, exactly what constitutes ‘without male protection’ is an ‘open question’ and possibly a subjective determination."

The full text of Aguilar-De Guillen v. Sessions: