BIA Holds PSG Defined Only by Noncitizen’s Sex or Sex and Nationality Is Overbroad

The BIA held that a particular social group (PSG) defined by a noncitizen’s sex or sex and nationality, standing alone, is overbroad and insufficiently particular to be cognizable. The BIA thus concluded that the respondent’s proposed PSG of Salvadoran women did not satisfy the particularity requirement for a cognizable group. The BIA further found that the respondent’s second proposed group of Salvadoran women viewed as property also lacked the requisite particularity for a cognizable PSG. Accordingly, the BIA dismissed the respondent’s appeal. Matter of K-E-S-G-, 29 I&N Dec. 145 (BIA 2025)