Umana-Ramos v. Holder, No. 12-4274 (CA6 July 30, 2013) (published)
In this resistance to gang recruitment case, the Court clearly adopted the BIA's particular social group test, which requires a showing of particularity and social visibility. The Court did so with a caveat - social visibility is not to be taken literally (there is no on-sight visibility requirement). Rather, it means that individuals with a shared characteristic must be perceived as a group in the society at issue.
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