The Second Circuit has determined that “[t]o hold categorically that an applicant for CAT relief must be threatened more than once and that such a person must suffer physical harm before fleeing is an error of law.” “Martinez’s testimony, which the IJ credited, established that she and her children were facing a sustained 17 campaign of violent confrontations. These included when gang 18 members flashed a knife at Martinez and when they attempted to force Martinez’s pregnant daughter into a secluded area and threatened to cut her child out of her body.”

The full text of Martinez De Artiga v. Barr can be found here:

ca2.uscourts.gov/decisions/isysquery/0c7b55a5-be7b-43f5-ac93-5989936afec3/7/doc/17-2898_complete_opn.pdf#xml=https://www.ca2.uscourts.gov/decisions/isysquery/0c7b55a5-be7b-43f5-ac93-5989936afec3/7/hilite/

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