This Law Summary first focuses on the development of the various approaches by the U.S. immigration court system in defining the term particular social group. Second, it discusses the cryptic evolution of the social visibility doctrine. Finally, it will explore how the conflicting applications of the social visibility doctrine among the U.S. courts of appeals have resulted in potentially unpredictable outcomes for those seeking protection in the United States, and it will suggest that a clarification of the social visibility doctrine by either the BIA or Supreme Court would alleviate the conflict.

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