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Abstract: 

This article examines the July 2025 Board of Immigration Appeals decision in Matter of K-E-S-G-, which sharply narrows asylum eligibility for survivors of gender-based violence, including domestic violence. By rejecting sex—or sex plus nationality—as a valid “particular social group,” the ruling dismantles a critical legal pathway long relied upon by women fleeing abuse where governments are unwilling or unable to protect them. Tracing the evolution of U.S. asylum law from international refugee principles through recent political reversals, the article explains why this decision represents a profound setback for survivor protection. It also explores the real-world consequences for women forced to choose between legal denial and return to life-threatening violence.

Keywords: Asylum Law; Domestic Violence; Gender-Based Violence; Particular Social Group; Immigration Courts

Affiliations:  1: Editor.