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BIA Rules on Establishing Particular Social Group Based on Landownership.  The BIA ruled that landowner status does not automatically render membership into a particular social group for asylum and withholding of removal, and landowners and landowners who resist drug cartels in Guatemala are not particular social groups. Matter of E-R-A-L-, 27 I&N Dec. 767 (BIA 2020)

AILA Doc. No. 20021035