The Tenth Circuit has reversed the agency’s determination that a Ghanian asylum seeker could safely relocate within Ghana to escape harm from a rival tribe. “The government has offered no evidence that Atwode are not present in other Ghanaian cities to which it would have Petitioner relocate. And more importantly, the government has no evidence linking the Atwode’s ability to track and threaten Petitioner in Accra with the ‘presence’ of Atwode migrants in that city. The government has thus failed to satisfy its burden to show that Petitioner’s experience in Accra––where he apparently was tracked, threatened, and shot at by Atwode as he moved from address to address––could not be duplicated in other parts of Ghana.”
The full text of Addo v. Barr can be found here: