Practice Advisory: Navigating Family-Based Claims Following Matter of M-R-M-S

On December 1, 2023, the Board of Immigration Appeals issued a precedential decision, Matter of M‑R‑M‑S‑, 28 I&N Dec. 757 (BIA 2023), which purports to narrow the circumstances in which asylum seekers can prove that their membership in a family-based particular social group can meet the “one central reason” nexus standard. This practice advisory discusses the BIA opinion, explains how it intersects with existing court of appeals case law, and provides practical tips for practitioners on how to frame family-based asylum cases going forward.