Title	Brief of the United Nations High Commissioner for Refugees before the United States Court of Appeals for the First Circuit in the case O.L.B.D., petitioner, v. William P. Barr, Attorney General, respondent
Publisher	UN High Commissioner for Refugees (UNHCR)
Publication Date	11 March 2019
Country	El Salvador | United States of America
Topics	Domestic violence | Non-state agents of persecution | Social group persecution | State protection
Citation / Document Symbol	NO. 18-1816 (A206-252-605)
Cite as	UN High Commissioner for Refugees (UNHCR), Brief of the United Nations High Commissioner for Refugees before the United States Court of Appeals for the First Circuit in the case O.L.B.D., petitioner, v. William P. Barr, Attorney General, respondent, 11 March 2019, NO. 18-1816 (A206-252-605), available at: https://www.refworld.org/docid/5c8924454.html [accessed 1 November 2019]
Comments	UNHCR has a specific interest in this matter because the Board rested its decision on the former Attorney General’s decision in Matter of A-B-, 27 I. & N. Dec. 316 (A.G. 2018), which diverges from UNHCR’s authoritative interpretation of States’ obligations under the 1951 Convention and 1967 Protocol in several key respects. In particular, the decision conflicts with UNHCR’s interpretations of (1) the definition of a “particular social group,” (2) the standard used to assess whether states are “unable or unwilling” to provide effective protection against non-state agents of persecution, and (3) the “nexus” requirement concerning whether persecution by non-state actors is “on account of” membership in a particular social group.