The Ninth Circuit has determined that an asylum seeker who must remain in hiding to avoid harm cannot reasonably relocate in her country of origin. Though recognizing the regulations governing protection under the Convention Against Torture (unlike those related to asylum and withholding of removal) do not explicitly require internal relocation to be “reasonable,” the court assumed that the analysis would remain the same. The court also rejected the agency’s analysis of the social distinction of the petitioner’s proposed social group consisting of “women resistant to forced marriage proposals,” finding that the requisite distinction was established by the petitioner’s testimony that she was ostracized for refusing a local ruler’s marriage proposal, and that the local ruler has to authority to enforce traditional law in other parts of the country, allowing him in the past to hunt down women who refused his marriage proposals. Finally, the court recognized that inherent in the concept of forced marriage is forced rape, which would qualify as a form of torture.
The full text of Akosung v. Barr can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/08/14/17-72829.pdf