The Third Circuit has remanded a case in which the agency found the petitioner did not suffer past persecution simply because the harm she experienced was limited to verbal threats. The court directed the agency to consider the cumulative effect of the threats.
“Thus, a threat is ‘concrete and menacing,’ constituting past persecution, where the aggregate effect of a petitioner’s experiences, including or culminating in the threat in question, placed a petitioner’s life in peril or created an atmosphere of fear so oppressive that it severely curtailed the petitioner’s liberty.“ The court noted that even in the absence of physical harm to the petitioner, the agency should consider the threats in conjunction with violence against her property and close associates.
The full text of Herrera-Reyes v. AG can be found here:
https://www2.ca3.uscourts.gov/opinarch/192255p.pdf