Law Firm of Bryant R. Camareno, Board Certified Criminal Trial Lawyer

09/06/2026

The Board of Immigration Appeals has issued a decision in Matter of A-E-V-M-, 30 I&N Dec. 20 (BIA 2026).

(1) The removal of former President Maduro from power and the ensuing transfer of executive authority constitute a change in country conditions in Venezuela for purposes of assessing an applicant’s prospective fear of persecution.

(2) Remand is required because the Immigration Judge did not sufficiently assess the effect of the changed country conditions on the respondent’s particularized risk of future persecution.

08/21/2026

“[W]here ․ a defendant has been found incompetent to proceed and is then released upon conditions and commits a new offense, section 916.17(2)[, Florida Statutes,] leaves the trial judge with only two options: modify the conditions of release or involuntarily commit the defendant to DCFS for treatment.” Douse v. State, 930 So. 2d 838, 839 (Fla. 4th DCA 2006); accord Paolercio v. State, 129 So. 3d 1174, 1175–76 (Fla. 5th DCA 2014) (citing Douse, 930 So. 2d at 839).

08/16/2026

The Board of Immigration Appeals has issued a decision in Matter of A-G-O-F-, 29 I&N Dec. 772 (BIA 2026).

(1) “Brazilian children” and “abandoned Brazilian children” are not cognizable particular social groups because they are not defined with sufficient particularity.

(2) The Immigration Judge clearly erred in determining that the respondent’s past harm was perpetrated by individuals that the government of Brazil was unable or unwilling to control when the government arrested one of the perpetrators in connection with other crimes, the respondent has not shown that the other perpetrator is still at large because of an inability or unwillingness of the government to investigate and punish his crimes, and the government provides services for abused children to help authorities protect them.

(3) The respondent did not establish eligibility for humanitarian asylum because he did not show that the government was unwilling or unable to protect him from the harm he suffered in the past.

08/16/2026

The Board of Immigration Appeals has issued a decision in Matter of H-L-S-M-, 29 I&N Dec. 767 (BIA 2026).

(1) The Immigration Judge clearly erred in finding it more likely than not the applicant will be tortured if removed to either Mexico or Guatemala based on general country conditions evidence and expert witness testimony about corruption while overlooking key facts regarding the applicant’s individualized circumstances, including lack of past torture, the passage of time since the applicant received threats, and the vague and indirect nature of the threats.

(2) The applicant did not establish that a public official is likely to acquiesce to his torture by gang members where the record shows elements within the government have taken action to combat criminal organizations, even if such efforts have not been effective.

08/05/2026

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