African Immigrant Rights Council

FROM THE DESK OF EXECUTIVE DIRECTOR, SHARIFA KALOKOLA

January 23, 2026

No relief for woman because her abusive ex-partner was

no longer interested in harming her
Ms. “DG” was abused and threatened by her ex-partner in Mexico; so she fled
and arrived in the United States in 2023.
The BIA denied relief, ruling that, Yes, she had been “severely harmed,” but
there was no “objective evidence that he would be aware of her return to Mexico or that he would be actively looking for her.”
There was no real evidence that the ex-partner “currently has any interest in her.”
There was no “objective” evidence showing that he has “any present
continuing interest in harming her.”
The BIA said, in essence, “Your ex-partner has forgotten about you.
Prove he has not.” Matter of D-G-B-L-, 29 I&N Dec 392 [BIA 2026]

MORAL OF THE STORY: be prepared to answer these questions:
Is there anyone in your country who believes your persecutor is still
interested in you? Did that person write a letter of support for you? Why not?
If no one in your country believes your persecutor has a present,
continuing interest in harming you, why should I, the Judge, believe that?

This case underscores the importance of presenting concrete, current evidence of a persecutor’s ongoing intent to harm, not just past abuse. Survivors and advocates must anticipate this burden and prepare supporting documentation early.