The Board of Immigration Appeals has held that a Pennsylvania conviction for possession with intent to deliver a controlled substance was a particularly serious crime. The respondent, a transgender woman from Jamaica, had previously been granted asylum, and DHS appealed.

The Board found that the offense involved serious drug trafficking conduct, including a significant sentence and circumstances showing a large packaged quantity of marijuana and attempted concealment from police. The Board also denied CAT protection, finding that past harm was inflicted by private actors and that the respondent had not shown likely government acquiescence in future torture. The Board sustained DHS’s appeal and ordered removal to Jamaica.

The full text of Matter of G-L-C- can be found here: https://www.justice.gov/eoir/media/1449211/dl?inline

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