INA §237(a)(4) Security, Terrorism, Foreign Policy, Atrocity, and Religious Freedom Grounds

INA §237(a)(4)(E): Severe Violations of Religious Freedom Deportability

INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). This page focuses on the charge, proof, incorporated definitions, relief consequences, and preservation.

Reviewed by Peter Messersmith September 18, 2026

Direct Answer

INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. The charge should identify the qualifying official role and the conduct attributed to it.

Core Rule

religious-freedom official-responsibility ground core rule applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief.

religious-freedom official-responsibility ground core rule applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings.

religious-freedom official-responsibility ground core rule applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling.

religious-freedom official-responsibility ground core rule applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence.

Statutory Text

religious-freedom official-responsibility ground statutory text applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection.

religious-freedom official-responsibility ground statutory text applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence.

religious-freedom official-responsibility ground statutory text applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently.

religious-freedom official-responsibility ground statutory text applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date.

Elements

religious-freedom official-responsibility ground elements applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources.

religious-freedom official-responsibility ground elements applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof.

religious-freedom official-responsibility ground elements applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding.

religious-freedom official-responsibility ground elements applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately.

Charging Theory

religious-freedom official-responsibility ground charging theory applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct.

religious-freedom official-responsibility ground charging theory applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct.

religious-freedom official-responsibility ground charging theory applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections.

religious-freedom official-responsibility ground charging theory applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof.

Burden

religious-freedom official-responsibility ground burden applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution.

religious-freedom official-responsibility ground burden applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling.

religious-freedom official-responsibility ground burden applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels.

religious-freedom official-responsibility ground burden applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause.

Evidence

religious-freedom official-responsibility ground evidence applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief.

religious-freedom official-responsibility ground evidence applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings.

religious-freedom official-responsibility ground evidence applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling.

religious-freedom official-responsibility ground evidence applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence.

Respondent Position

religious-freedom official-responsibility ground respondent position applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection.

religious-freedom official-responsibility ground respondent position applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence.

religious-freedom official-responsibility ground respondent position applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently.

religious-freedom official-responsibility ground respondent position applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date.

DHS Position

religious-freedom official-responsibility ground dhs position applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources.

religious-freedom official-responsibility ground dhs position applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof.

religious-freedom official-responsibility ground dhs position applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding.

religious-freedom official-responsibility ground dhs position applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately.

Judge Findings

religious-freedom official-responsibility ground judge findings applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct.

religious-freedom official-responsibility ground judge findings applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct.

religious-freedom official-responsibility ground judge findings applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections.

religious-freedom official-responsibility ground judge findings applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof.

Conduct or Conviction

religious-freedom official-responsibility ground conduct or conviction applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution.

religious-freedom official-responsibility ground conduct or conviction applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling.

religious-freedom official-responsibility ground conduct or conviction applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels.

religious-freedom official-responsibility ground conduct or conviction applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause.

Actor Status

religious-freedom official-responsibility ground actor status applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief.

religious-freedom official-responsibility ground actor status applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings.

religious-freedom official-responsibility ground actor status applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling.

religious-freedom official-responsibility ground actor status applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence.

Asylum Effect

religious-freedom official-responsibility ground asylum effect applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection.

religious-freedom official-responsibility ground asylum effect applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence.

religious-freedom official-responsibility ground asylum effect applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently.

religious-freedom official-responsibility ground asylum effect applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date.

Withholding and CAT

religious-freedom official-responsibility ground withholding and cat applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources.

religious-freedom official-responsibility ground withholding and cat applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof.

religious-freedom official-responsibility ground withholding and cat applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding.

religious-freedom official-responsibility ground withholding and cat applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately.

Appeal Preservation

religious-freedom official-responsibility ground appeal preservation applies this rule: General association with a government is not a substitute for statutory responsibility or direct participation. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct.

religious-freedom official-responsibility ground appeal preservation applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct.

religious-freedom official-responsibility ground appeal preservation applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections.

religious-freedom official-responsibility ground appeal preservation applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof.

Checklist

religious-freedom official-responsibility ground checklist applies this rule: The Immigration Judge should keep this ground distinct from persecution, terrorism, foreign-policy, and torture charges. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause. religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution.

religious-freedom official-responsibility ground checklist applies this rule: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G). religious-freedom official-responsibility ground should state the alleged conduct. religious-freedom official-responsibility ground should separate suspicion from proof. religious-freedom official-responsibility ground should test each element independently. religious-freedom official-responsibility ground should cite the source evidence. religious-freedom official-responsibility ground should challenge unreliable attribution. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling.

religious-freedom official-responsibility ground checklist applies this rule: The incorporated provision concerns foreign government officials responsible for or directly carrying out particularly severe violations of religious freedom. religious-freedom official-responsibility ground should separate group status from conduct. religious-freedom official-responsibility ground should identify any knowledge finding. religious-freedom official-responsibility ground should record the activity date. religious-freedom official-responsibility ground should separate removability from relief. religious-freedom official-responsibility ground should request a burden ruling. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels.

religious-freedom official-responsibility ground checklist applies this rule: The charge should identify the qualifying official role and the conduct attributed to it. religious-freedom official-responsibility ground should preserve evidence objections. religious-freedom official-responsibility ground should identify exemption authority separately. religious-freedom official-responsibility ground should state remaining protection. religious-freedom official-responsibility ground should obtain reviewable findings. religious-freedom official-responsibility ground should avoid conclusory labels. religious-freedom official-responsibility ground should compare charge and proof. religious-freedom official-responsibility ground should document information sources. religious-freedom official-responsibility ground should address contrary evidence. religious-freedom official-responsibility ground should request a clause-specific ruling. religious-freedom official-responsibility ground should identify the incorporated clause.

Primary Legal Authorities and Sources

8 U.S.C. §1227(a)(4) — Security and Related Grounds Current INA §237(a)(4) security and related deportability grounds.
8 U.S.C. §1182(a)(3) — Security and Related Grounds Current terrorism, foreign-policy, and atrocity definitions incorporated into INA §237(a)(4).
EOIR BIA Precedent Chart Official EOIR precedent index.
8 C.F.R. §1240.8 — Burdens in Removal Proceedings Current removal and relief burden regulation.
8 C.F.R. §1208.13 — Asylum Eligibility Current asylum regulation and security bars.
8 C.F.R. §1208.16 — Withholding and CAT Current withholding and CAT regulation.

Frequently Asked Questions

What is the rule for INA 237(a)(4)(E) severe violations religious freedom deportability?

religious-freedom official-responsibility ground: INA §237(a)(4)(E) makes deportable a person described in the severe-violations-of-religious-freedom provision incorporated from INA §212(a)(2)(G).

Does INA 237(a)(4)(E) severe violations religious freedom deportability require a conviction?

religious-freedom official-responsibility ground requires reading the exact clause. Several security grounds are conduct based.

What burden applies to INA 237(a)(4)(E) severe violations religious freedom deportability?

religious-freedom official-responsibility ground remains within DHS's clear-and-convincing removability burden.

Can INA 237(a)(4)(E) severe violations religious freedom deportability affect asylum?

religious-freedom official-responsibility ground can overlap with separate asylum and withholding bars.

What evidence matters for INA 237(a)(4)(E) severe violations religious freedom deportability?

religious-freedom official-responsibility ground requires evidence tied to the specific statutory element and source.

How is INA 237(a)(4)(E) severe violations religious freedom deportability preserved for appeal?

religious-freedom official-responsibility ground should produce findings on clause, burden, evidence, conduct, and relief effect.

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