The Ninth Circuit has determined that there is no de minimis exception to the material support to terrorism bar. In so doing, the court found that statute was unambiguous, but held that even if it were, it would defer to the Board of Immigration Appeals’ decision in Matter of A-C-M-. The panel held that because petitioner admitted that he gave about $50 to someone whom he knew was a member of the Maoists, a designated terrorist organization at that time, substantial evidence supported the Board’s determination that he gave material support to a terrorist organization, rendering him ineligible for asylum and withholding of removal.
The full text of Rayamajhi v. Whitaker can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/01/15/16-70534.pdf