The Ninth Circuit has sustained the appeal of an asylum applicant who moved to reopen her proceedings after her abusive husband was deported to India, and her in-laws threatened to kill her if she returned. The court emphasized that a change in personal circumstances completely outside the applicant’s control can support reopening. The court also noted that increasing violence against women (especially widows) in India supported reopening of the case.
The full text of Kaur v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/06/21/18-72786.pdf