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

Material Support Under Duress After Matter of M-H-Z-

Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. This page focuses on the charge, proof, incorporated definitions, relief consequences, and preservation.

Reviewed by Peter Messersmith September 18, 2026

Direct Answer

Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements.

Core Rule

M-H-Z compelled-support doctrine core rule applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief.

M-H-Z compelled-support doctrine core rule applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings.

M-H-Z compelled-support doctrine core rule applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling.

M-H-Z compelled-support doctrine core rule applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence.

Statutory Text

M-H-Z compelled-support doctrine statutory text applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection.

M-H-Z compelled-support doctrine statutory text applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence.

M-H-Z compelled-support doctrine statutory text applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently.

M-H-Z compelled-support doctrine statutory text applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date.

Elements

M-H-Z compelled-support doctrine elements applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources.

M-H-Z compelled-support doctrine elements applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof.

M-H-Z compelled-support doctrine elements applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding.

M-H-Z compelled-support doctrine elements applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately.

Charging Theory

M-H-Z compelled-support doctrine charging theory applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct.

M-H-Z compelled-support doctrine charging theory applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct.

M-H-Z compelled-support doctrine charging theory applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections.

M-H-Z compelled-support doctrine charging theory applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof.

Burden

M-H-Z compelled-support doctrine burden applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution.

M-H-Z compelled-support doctrine burden applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling.

M-H-Z compelled-support doctrine burden applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels.

M-H-Z compelled-support doctrine burden applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause.

Evidence

M-H-Z compelled-support doctrine evidence applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief.

M-H-Z compelled-support doctrine evidence applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings.

M-H-Z compelled-support doctrine evidence applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling.

M-H-Z compelled-support doctrine evidence applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence.

Respondent Position

M-H-Z compelled-support doctrine respondent position applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection.

M-H-Z compelled-support doctrine respondent position applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence.

M-H-Z compelled-support doctrine respondent position applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently.

M-H-Z compelled-support doctrine respondent position applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date.

DHS Position

M-H-Z compelled-support doctrine dhs position applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources.

M-H-Z compelled-support doctrine dhs position applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof.

M-H-Z compelled-support doctrine dhs position applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding.

M-H-Z compelled-support doctrine dhs position applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately.

Judge Findings

M-H-Z compelled-support doctrine judge findings applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct.

M-H-Z compelled-support doctrine judge findings applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct.

M-H-Z compelled-support doctrine judge findings applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections.

M-H-Z compelled-support doctrine judge findings applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof.

Conduct or Conviction

M-H-Z compelled-support doctrine conduct or conviction applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution.

M-H-Z compelled-support doctrine conduct or conviction applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling.

M-H-Z compelled-support doctrine conduct or conviction applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels.

M-H-Z compelled-support doctrine conduct or conviction applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause.

Actor Status

M-H-Z compelled-support doctrine actor status applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief.

M-H-Z compelled-support doctrine actor status applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings.

M-H-Z compelled-support doctrine actor status applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling.

M-H-Z compelled-support doctrine actor status applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence.

Asylum Effect

M-H-Z compelled-support doctrine asylum effect applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection.

M-H-Z compelled-support doctrine asylum effect applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence.

M-H-Z compelled-support doctrine asylum effect applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently.

M-H-Z compelled-support doctrine asylum effect applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date.

Withholding and CAT

M-H-Z compelled-support doctrine withholding and cat applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources.

M-H-Z compelled-support doctrine withholding and cat applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof.

M-H-Z compelled-support doctrine withholding and cat applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding.

M-H-Z compelled-support doctrine withholding and cat applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately.

Appeal Preservation

M-H-Z compelled-support doctrine appeal preservation applies this rule: Congress provided separate exemption authority rather than an adjudicator-created duress exception. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct.

M-H-Z compelled-support doctrine appeal preservation applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct.

M-H-Z compelled-support doctrine appeal preservation applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections.

M-H-Z compelled-support doctrine appeal preservation applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof.

Checklist

M-H-Z compelled-support doctrine checklist applies this rule: CAT deferral and any available exemption should be analyzed separately from the threshold finding. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution.

M-H-Z compelled-support doctrine checklist applies this rule: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception. M-H-Z compelled-support doctrine should state the alleged conduct. M-H-Z compelled-support doctrine should separate suspicion from proof. M-H-Z compelled-support doctrine should test each element independently. M-H-Z compelled-support doctrine should cite the source evidence. M-H-Z compelled-support doctrine should challenge unreliable attribution. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling.

M-H-Z compelled-support doctrine checklist applies this rule: Support can therefore satisfy the statutory bar even when the respondent credibly establishes coercion. M-H-Z compelled-support doctrine should separate group status from conduct. M-H-Z compelled-support doctrine should identify any knowledge finding. M-H-Z compelled-support doctrine should record the activity date. M-H-Z compelled-support doctrine should separate removability from relief. M-H-Z compelled-support doctrine should request a burden ruling. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels.

M-H-Z compelled-support doctrine checklist applies this rule: The absence of a duress defense does not eliminate the need to prove the recipient, support, and remaining statutory elements. M-H-Z compelled-support doctrine should preserve evidence objections. M-H-Z compelled-support doctrine should identify exemption authority separately. M-H-Z compelled-support doctrine should state remaining protection. M-H-Z compelled-support doctrine should obtain reviewable findings. M-H-Z compelled-support doctrine should avoid conclusory labels. M-H-Z compelled-support doctrine should compare charge and proof. M-H-Z compelled-support doctrine should document information sources. M-H-Z compelled-support doctrine should address contrary evidence. M-H-Z compelled-support doctrine should request a clause-specific ruling. M-H-Z compelled-support doctrine should identify the incorporated clause.

Primary Legal Authorities and Sources

Matter of M-H-Z-, 26 I&N Dec. 757 (BIA 2016) BIA precedent rejecting an implied duress exception to the material-support bar.
Matter of S-K-, 23 I&N Dec. 936 (BIA 2006) BIA precedent on terrorist organizations, material support, intent, and intended use.
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 Precedent Decisions — Volume 26 Official EOIR volume containing Matter of Tavarez-Peralta and Matter of Vides Casanova.
8 U.S.C. §1227(a)(4) — Security and Related Grounds Current INA §237(a)(4) security and related deportability grounds.
8 C.F.R. §1240.8 — Burdens in Removal Proceedings Current removal and relief burden regulation.

Frequently Asked Questions

What is the rule for Matter of M-H-Z material support duress terrorism deportability?

M-H-Z compelled-support doctrine: Matter of M-H-Z- holds that the material-support provision does not contain an implied duress exception.

Does Matter of M-H-Z material support duress terrorism deportability require a conviction?

M-H-Z compelled-support doctrine requires reading the exact clause. Several security grounds are conduct based.

What burden applies to Matter of M-H-Z material support duress terrorism deportability?

M-H-Z compelled-support doctrine remains within DHS's clear-and-convincing removability burden.

Can Matter of M-H-Z material support duress terrorism deportability affect asylum?

M-H-Z compelled-support doctrine can overlap with separate asylum and withholding bars.

What evidence matters for Matter of M-H-Z material support duress terrorism deportability?

M-H-Z compelled-support doctrine requires evidence tied to the specific statutory element and source.

How is Matter of M-H-Z material support duress terrorism deportability preserved for appeal?

M-H-Z compelled-support doctrine should produce findings on clause, burden, evidence, conduct, and relief effect.

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