The Third Circuit has determined that its precedent does not require a showing of serious physical injury (or any physical harm at all) in order to demonstrate past persecution. Similarly, the court clarified that threats of harm need not be imminent in order to rise to the level of persecution.

The full text of Blanco v. Attorney General can be found here:

https://www2.ca3.uscourts.gov/opinarch/193658p.pdf

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