The Ninth Circuit has determined that if the government of the third country in which an asylum seeker has resettled is unable or unwilling to protect the asylum seeker from persecution by private parties, the asylum seeker qualifies for an exception to the firm resettlement bar. In this case, which involved a Somali citizen who had obtained refugee status in South Africa, the immigration judge had paradoxically found the petitioner firmly resettled in South Africa, but granted withholding of removal based on past persecution in South Africa.
The full text of Aden v. Wilkinson can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/03/04/17-71313.pdf