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

Torture and Extrajudicial Killing Deportability Under Matter of Vides Casanova

Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. This page focuses on the charge, proof, incorporated definitions, relief consequences, and preservation.

Reviewed by Peter Messersmith September 18, 2026

Direct Answer

Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova.

Core Rule

Vides command-responsibility attribution doctrine core rule applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief.

Vides command-responsibility attribution doctrine core rule applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings.

Vides command-responsibility attribution doctrine core rule applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling.

Vides command-responsibility attribution doctrine core rule applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence.

Statutory Text

Vides command-responsibility attribution doctrine statutory text applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection.

Vides command-responsibility attribution doctrine statutory text applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence.

Vides command-responsibility attribution doctrine statutory text applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently.

Vides command-responsibility attribution doctrine statutory text applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date.

Elements

Vides command-responsibility attribution doctrine elements applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources.

Vides command-responsibility attribution doctrine elements applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof.

Vides command-responsibility attribution doctrine elements applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding.

Vides command-responsibility attribution doctrine elements applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately.

Charging Theory

Vides command-responsibility attribution doctrine charging theory applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct.

Vides command-responsibility attribution doctrine charging theory applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct.

Vides command-responsibility attribution doctrine charging theory applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections.

Vides command-responsibility attribution doctrine charging theory applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof.

Burden

Vides command-responsibility attribution doctrine burden applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution.

Vides command-responsibility attribution doctrine burden applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling.

Vides command-responsibility attribution doctrine burden applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels.

Vides command-responsibility attribution doctrine burden applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause.

Evidence

Vides command-responsibility attribution doctrine evidence applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief.

Vides command-responsibility attribution doctrine evidence applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings.

Vides command-responsibility attribution doctrine evidence applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling.

Vides command-responsibility attribution doctrine evidence applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence.

Respondent Position

Vides command-responsibility attribution doctrine respondent position applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection.

Vides command-responsibility attribution doctrine respondent position applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence.

Vides command-responsibility attribution doctrine respondent position applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently.

Vides command-responsibility attribution doctrine respondent position applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date.

DHS Position

Vides command-responsibility attribution doctrine dhs position applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources.

Vides command-responsibility attribution doctrine dhs position applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof.

Vides command-responsibility attribution doctrine dhs position applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding.

Vides command-responsibility attribution doctrine dhs position applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately.

Judge Findings

Vides command-responsibility attribution doctrine judge findings applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct.

Vides command-responsibility attribution doctrine judge findings applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct.

Vides command-responsibility attribution doctrine judge findings applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections.

Vides command-responsibility attribution doctrine judge findings applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof.

Conduct or Conviction

Vides command-responsibility attribution doctrine conduct or conviction applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution.

Vides command-responsibility attribution doctrine conduct or conviction applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling.

Vides command-responsibility attribution doctrine conduct or conviction applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels.

Vides command-responsibility attribution doctrine conduct or conviction applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause.

Actor Status

Vides command-responsibility attribution doctrine actor status applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief.

Vides command-responsibility attribution doctrine actor status applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings.

Vides command-responsibility attribution doctrine actor status applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling.

Vides command-responsibility attribution doctrine actor status applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence.

Asylum Effect

Vides command-responsibility attribution doctrine asylum effect applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection.

Vides command-responsibility attribution doctrine asylum effect applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence.

Vides command-responsibility attribution doctrine asylum effect applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently.

Vides command-responsibility attribution doctrine asylum effect applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date.

Withholding and CAT

Vides command-responsibility attribution doctrine withholding and cat applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources.

Vides command-responsibility attribution doctrine withholding and cat applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof.

Vides command-responsibility attribution doctrine withholding and cat applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding.

Vides command-responsibility attribution doctrine withholding and cat applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately.

Appeal Preservation

Vides command-responsibility attribution doctrine appeal preservation applies this rule: The evidence must connect authority, knowledge, acts, and omissions to particular torture or extrajudicial killings. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct.

Vides command-responsibility attribution doctrine appeal preservation applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct.

Vides command-responsibility attribution doctrine appeal preservation applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections.

Vides command-responsibility attribution doctrine appeal preservation applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof.

Checklist

Vides command-responsibility attribution doctrine checklist applies this rule: The decision should identify the abuses and factual basis for command-responsibility attribution. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution.

Vides command-responsibility attribution doctrine checklist applies this rule: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility. Vides command-responsibility attribution doctrine should state the alleged conduct. Vides command-responsibility attribution doctrine should separate suspicion from proof. Vides command-responsibility attribution doctrine should test each element independently. Vides command-responsibility attribution doctrine should cite the source evidence. Vides command-responsibility attribution doctrine should challenge unreliable attribution. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling.

Vides command-responsibility attribution doctrine checklist applies this rule: The Board relied on command positions, awareness of abuses, interference with investigations, and failure to hold perpetrators accountable. Vides command-responsibility attribution doctrine should separate group status from conduct. Vides command-responsibility attribution doctrine should identify any knowledge finding. Vides command-responsibility attribution doctrine should record the activity date. Vides command-responsibility attribution doctrine should separate removability from relief. Vides command-responsibility attribution doctrine should request a burden ruling. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels.

Vides command-responsibility attribution doctrine checklist applies this rule: Direct personal commission of each underlying act was not required on the record found sufficient in Vides Casanova. Vides command-responsibility attribution doctrine should preserve evidence objections. Vides command-responsibility attribution doctrine should identify exemption authority separately. Vides command-responsibility attribution doctrine should state remaining protection. Vides command-responsibility attribution doctrine should obtain reviewable findings. Vides command-responsibility attribution doctrine should avoid conclusory labels. Vides command-responsibility attribution doctrine should compare charge and proof. Vides command-responsibility attribution doctrine should document information sources. Vides command-responsibility attribution doctrine should address contrary evidence. Vides command-responsibility attribution doctrine should request a clause-specific ruling. Vides command-responsibility attribution doctrine should identify the incorporated clause.

Primary Legal Authorities and Sources

Matter of Vides Casanova, 26 I&N Dec. 494 (BIA 2015) BIA precedent applying command responsibility to torture and extrajudicial killing.
EOIR BIA Precedent Chart REF-END Official EOIR precedent index for public-security and atrocity cases.
EOIR Precedent Decisions — Volume 26 Official EOIR volume containing Matter of Tavarez-Peralta and Matter of Vides Casanova.
8 U.S.C. §1182(a)(3) — Security and Related Grounds Current terrorism, foreign-policy, and atrocity definitions incorporated into INA §237(a)(4).
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 Vides Casanova torture extrajudicial killing command responsibility deportability?

Vides command-responsibility attribution doctrine: Matter of Vides Casanova holds that INA §237(a)(4)(D) can reach participation in torture and extrajudicial killing through command responsibility.

Does Matter of Vides Casanova torture extrajudicial killing command responsibility deportability require a conviction?

Vides command-responsibility attribution doctrine requires reading the exact clause. Several security grounds are conduct based.

What burden applies to Matter of Vides Casanova torture extrajudicial killing command responsibility deportability?

Vides command-responsibility attribution doctrine remains within DHS's clear-and-convincing removability burden.

Can Matter of Vides Casanova torture extrajudicial killing command responsibility deportability affect asylum?

Vides command-responsibility attribution doctrine can overlap with separate asylum and withholding bars.

What evidence matters for Matter of Vides Casanova torture extrajudicial killing command responsibility deportability?

Vides command-responsibility attribution doctrine requires evidence tied to the specific statutory element and source.

How is Matter of Vides Casanova torture extrajudicial killing command responsibility deportability preserved for appeal?

Vides command-responsibility attribution doctrine should produce findings on clause, burden, evidence, conduct, and relief effect.

Case Evaluation

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