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Matter of Toboso-Alfonso

United States Board of Immigration Appeals · 20 I&N Dec. 819 · Decided 1990; designated as precedent 1994 · United States

Key principle

SOGI as a particular social group under US refugee law.

Facts

A Cuban gay man sought asylum in the United States based on state harassment and mistreatment by Cuban authorities.

Legal questions

Are gay people who are subjected to state mistreatment a 'particular social group' under US asylum law?

Holding

Yes. Gay people subjected to state mistreatment may constitute a particular social group for US protection.

Practical relevance

Founding US administrative precedent for SOGI asylum. Later designated as precedent by the Attorney General in 1994.

Limitations

US-specific administrative law; later case-law and regulatory developments must still be checked.

Official source

US Department of Justice — EOIR

Last reviewed: 2026-07-17

General information only. ImmigrationLGBT is not a law firm and this summary is not personalised legal advice. Consult a qualified lawyer or accredited representative in the relevant jurisdiction. Legal status and subsequent treatment of the decision may have changed.