Memorandum: Notification of Ramos v. Holder; Former Gang Membership as a Potential Particular Social Group in the Seventh Circuit [open pdf - 282KB]
"This memorandum provides notification to the Asylum Offices regarding the Seventh Circuit's recent decision in Ramos v. Holder, 589 F. 3d 426 (7th Cir. 2009). The Seventh Circuit issued its decision in Ramos on December 15,2009, holding that former gang membership can be the basis for a particular social group. The decision vacated the Board of Immigration Appeals' (Board 's) decision and the case was remanded to the Board for reconsideration in light of the Seventh Circuit's opinion."
HQRAIO 120/ 16b
U.S. Citizenship and Immigration Services: http://www.uscis.gov/