The Ninth Circuit reversed the Board of Immigration Appeals' denial of a motion to reopen based on changed country conditions for an Indonesian convert to Catholicism.  The court noted that the country conditions evidence of increased violence against Christians and the declaration from the petitioner's sister about her own experience as a Christian in Indonesia were sufficient to show changed circumstances, and when analyzed under the disfavored group analysis, sufficient to show a risk of individualized harm.  As such, the court deemed the petitioner prima facie eligible for asylum.

The full text of Salim v. Lynch can be found here:

http://cdn.ca9.uscourts.gov/datastore/opinions/2016/08/01/13-71833.pdf

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