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Fifth Circuit Finds "Business Owners" are not Valid PSG


September 26, 2023
by Sabrina Damast

The Fifth Circuit has determined that “business owners” are not a valid particular social group because they lack an immutable characteristic.

The full text of Munoz-De Zelaya v. Garland can be found here:

https://www.ca5.uscourts.gov/opinions/pub/22/22-60505-CV0.pdf

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