After over a decade of advocacy on behalf of women fleeing their home countries because of horrific domestic violence, practitioners and legal scholars obtained a precedential legal victory in August 2014. In In re A-R-C-G-, the Board of Immigration Appeals recognized that domestic violence can constitute persecution within the meaning of the Immigration and Nationality Act, and that nationality, gender, and the inability to leave a marital relationship can form the basis of a proper social group under the Act. Children fleeing intrafamilial violence, however, continue to face an uphill battle in seeking asylum. Widespread disparities in the outcomes of asylum adjudications in general demonstrate a need for uniformity and consistency. This Note argues that In re A-R-C-G-'s rationale applies to children's asylum claims that are based upon intrafamilial violence.

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