The Ninth Circuit has remanded a case in which the Board of Immigration Appeals denied a motion to reopen to seek protection under the Convention Against Torture (CAT) based on changed country conditions in Ethiopia for the LGBT community. In so doing, the court noted that "at least two of the reports submitted with Agonafer’s motion to reopen provide reports of violence directed against homosexuals in Ethiopia." "It is undisputed that Agonafer is a homosexual male. Given Agonafer’s sexual orientation and the evidence of the treatment of homosexuals in Ethiopia, there is sufficient evidence that, if proved, would establish his prima facie eligibility for deferral of removal under the CAT."
The full text of Agonafer v. Sessions can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2017/06/23/13-73122.pdf