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Ninth Circuit on Changed Circumstances

In Vahora v. Holder, the Ninth Circuit Court of Appeals examined “changed circumstances” as it pertains to the one-year bar to political asylum.  The Court held that “changed circumstances” do not necessarily require a completely new conflict in the applicant’s country of origin nor does it preclude an applicant who has always feared persecution from applying for asylum after one year if the fear increases due to changes in the country.

The Court also held that a person is not required to apply for asylum if her claim is a weak one, rather she can wait and if the conditions change to the extent that her claim becomes one that may entitle her to relief, she may be able to prove “changed circumstances” to waive the one-year bar to applying for political asylum.

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