The Fourth Circuit has rejected the Board of Immigration Appeals’ determination that even de minimis support of a terrorist organization disqualifies a non-citizen from asylum, finding that the agency’s interpretation reads the requirement that support be “material” out of the statute. Rather, the Court determined that “material support” is support that is sufficiently substantial standing alone to help the terrorist organization accomplish its terrorist activities. Thus, a captive laborer who cooked meals using food and supplies purchased by the organization did not provide the organization with material support.
The full text of Ozurumba v. Bondi can be found here: https://www.ca4.uscourts.gov/opinions/242070.P.pdf