Not defined in the INA – look to case law
Poverty, victim of crime, bad luck not enough
Behavior that “threatens death, imprisonment, or the infliction of substantial harm or suffering.”
- Sayaxing v. INS, 179 F.S3d 515, 519 (7th Cir. 1999).
“Hallmarks” of persecution are:
- detention, arrest, interrogation, prosecution, imprisonment,
- illegal searches, confiscation of property, surveillance, beatings, or torture
Mitev v. INS, 67 F.3d 1325, 1330 (7th Cir. 1995)