The First Circuit has remanded a motion to reopen filed by an indigenous Guatemalan seeking asylum. The court concluded that conditions had worsened for indigenous activists, and that the deportation of a military leader responsible for atrocities against the indigenous community (including several of the petitioner’s relatives) also constituted a changed condition.

The full text of Perez-Tino v. Barr can be found here:

http://media.ca1.uscourts.gov/pdf.opinions/18-1860P-01A.pdf

Comment