For the nearly four decades since international refugee protections were codified in U.S. law, uncertainty has existed regarding whether survivors of intimate partner violence comprise a “particular social group” (“PSG”) that entitles them to asylum protection in the United States.1 Litigation in the first domestic-violence-based asylum case to reach the Board of Immigration Appeals (“BIA”), Matter of R-A-,2 dragged on for fourteen years without resulting in precedent. Thereafter, in a move that would astonish strict adherents of civil procedure, advocates seeking asylum for clients who had endured intimate partner abuse would cite a brief authored by the Department of Homeland Security in another domestic violence asylum case, Matter of L-R-, in support of their arguments.3 Then, in 2014, the BIA issued a decision in Matter of A-R-C-G- that definitively established the right to asylum for survivors of intimate partner violence.4 The Board granted relief to Ms. C-G- based on her membership in the particular social group of “married women in Guatemala who are unable to leave their relationship.”