third Circuit Non-precedential Decision from 1/29/2021

The Third Circuit released two immigration decisions today, as far as I can tell: Paul v. Att'y Gen., No-20-1979, (3d Cir. 2021) (unpublished) and Patel v. Att'y Gen., No. 20-2018 (3d Cir. 2021) (unpublished).  Focusing on Paul, a panel of Greenaway, Krause, and Bibas denied, per curiam, Paul's petition for review.  The opinion reasons that Immigration Judge John B. Carle did not err in finding that Paul's proposed particular social group, "Haitian homeless," did not meet the "particularity requirement to be a cognizable social group because it was vast, diffuse, and amorphous."  Id. at 4.  Further, the panel found that the IJ Carle did not err in finding that Paul's experiences in Haiti did not amount to torture where he had once been involved in a violent robbery."  Id. at 5.

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