Maria D. Amezcua-Preciado v. U.S. Attorney General, 943 F.3d 1337

Maria Amezcua-Preciado, a Mexican national, arrived at the U.S. border with two minor children, conceded removability, and applied for asylum and withholding of removal based on domestic-violence persecution.
She testified to repeated physical and psychological abuse by her husband, threats to kill her if she left, limited family support, inability to afford relocation, and few effective police responses; she submitted affidavits and the U.S. State Department country report on Mexico.
The IJ found her credible, relied on Matter of A-R-C-G- to recognize the proposed group "women in Mexico who cannot leave their domestic relationships," and granted asylum.
DHS appealed; while the appeal was pending the Attorney General issued Matter of A-B-, overruling A-R-C-G- and holding most domestic-violence–based groups are not cognizable as particular social groups.
The BIA, applying A-B-, reversed the IJ, concluding Amezcua-Preciado’s proposed group was impermissibly defined by the harm, overbroad, and lacked social distinctiveness; it denied asylum and withholding.
The Eleventh Circuit affirmed, holding the proposed group is not a cognizable particular social group under the INA for the reasons the BIA articulated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "women in Mexico who are unable to leave their domestic relationships" is a cognizable "particular social group" for asylum/withholding	Amezcua-Preciado: group is defined by an immutable trait (being women) plus the shared circumstance of inability to leave, and she faces a well-founded fear of persecution	DHS/BIA: group is defined by the harm (risk of private violence), is overbroad and lacks social distinction; A-B- forecloses such domestic-violence–based groups absent exceptional circumstances	Held: Not cognizable; group is circular (defined by persecution), overbroad, and lacks societal recognition, so asylum/withholding denied
Whether Chevron deference applies to the Attorney General/BIA precedent invoked	Amezcua-Preciado: BIA/AG interpretation should not control if unreasonable	DHS/BIA: A-B- is a reasonable interpretation entitled to Chevron deference; even without deference, group fails under circuit precedent	Held: Court defers to A-B- as reasonable but states petition fails with or without Chevron deference

Perez-Zenteno v. U.S. Att’y Gen., 913 F.3d 1301 (11th Cir. 2019) (defines features of a "particular social group" and evaluates group cognizability)
Castillo-Arias v. U.S. Att’y Gen., 446 F.3d 1190 (11th Cir. 2006) (risk-of-persecution alone does not create a particular social group)
Gonzalez v. U.S. Att’y Gen., 820 F.3d 399 (11th Cir. 2016) (particularity requirement: group must have definable boundaries)
INS v. Aguirre-Aguirre, 526 U.S. 415 (1999) (Attorney General’s immigration interpretations may receive Chevron deference)
Chevron U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (1984) (agency interpretations of ambiguous statutes entitled to deference if reasonable)
Tan v. U.S. Att’y Gen., 446 F.3d 1369 (11th Cir. 2006) (standard for withholding of removal; higher burden than asylum)
Rodriguez v. U.S. Att’y Gen., 735 F.3d 1302 (11th Cir. 2013) (family members targeted by criminal groups did not form a particular social group)
Gonzales-Veliz v. Barr, 938 F.3d 219 (5th Cir. 2019) (holds a similar proposed group of women unable to leave relationships not cognizable under A-B-)
S.E.R.L. v. U.S. Att’y Gen., 894 F.3d 535 (3d Cir. 2018) (similar holding regarding family members of women unable to leave domestic relationships)