Law Commons^™

A Call For Refuge: The Case Of Forced Marriages, Emily A. Harrell

Emily A Harrell

This case note examines the ramifications of the Second Circuit Court of Appeal’s recent decision in Gao v. Gonzalez, 440 F.3d 62 (2d Cir. 2006), holding that women who were forced into marrying within a Chinese community where forced marriage was condoned and enforceable qualified as a “particular social group” eligible for asylum within the meaning of the Immigration and Nationality Act. Gao brings into question the position of the United States and the duties owed to refugees in such circumstances. This issue is particularly significant given the demonstrated concern for human rights as manifested by the United States accession …