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Asylum Defense in 2026: How to Build the Trial Record and Plead PSG Claims After Urias-Orellana

A thin trial record or a loosely pled social group can sink an asylum claim—and the 2026 standards raised the bar on both. Walk out with the checklists to front-load your evidence, defend against pretermission, and plead PSG definitions that hold up.

2026-08-06 13:00:00

2 hours

Program Details

2026-08-06 13:00:00

Program Details

2026-08-06 13:00:00

Over 1,000+ webinars

2026-08-06 13:00:00

2 hours

Course Overview

Asylum Defense Got Harder—At the Record and the Pleading

2026-08-06 13:00:00

The Supreme Court’s 2026 decision in Urias-Orellana v. Bondi holds that substantial evidence governs the entire persecution determination. That changes what you must build into the trial record—before the immigration judge ever rules.

Miss the pretermission window, and EOIR PM 25-28 and Matter of H-A-A-V- can end the case before a hearing. Fall short on corroboration, and Matter of G-C-I- and the I-589 completeness rules cut against you. Plead the social group loosely, and the revived Matter of A-B- I hands the agency its denial.

You leave with a record-building checklist tuned to the new standard, viable PSG formulations that survive particularity and circularity, arguments to challenge the agency’s unlawful standards, and a clear read on which claims still win.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Substantial evidence
Build the trial record to the standard Urias-Orellana now applies across the entire persecution determination.
02
Pretermission
Defend the record against EOIR PM 25-28 and Matter of H-A-A-V-.
03
Corroboration
Meet tightened standards under Matter of G-C-I- and the REAL ID Act.
04
PSG formulation
Build viable definitions under new particularity and circularity interpretations.
05
A-B- dicta
Argue around the general rule against private-violence claims and heightened protection.
06
Circuit conflicts
Leverage conflicting appellate authority and post-Loper Bright deference arguments.

Program schedule

clock 1:00 pm - 2:00 pm EST

Building the Asylum Trial Record After Urias-Orellana

Examine how Urias-Orellana v. Bondi—holding substantial evidence governs the persecution determination—changes the trial record, how EOIR PM 25-28 and Matter of H-A-A-V- compress the window through pretermission, and how recent BIA decisions tighten corroboration and I-589 completeness.

Daniella PrieshoffDaniella Prieshoff
clock 2:10 pm - 3:10 pm EST

PSG and Gender-Based Claims After Matter of K-E-S-G- & S-S-F-M-

Examine how Matter of K-E-S-G- and Matter of S-S-F-M-, which resurrect Matter of A-B- I, reshape pleading particular social groups and domestic violence-based claims, and learn to formulate PSG definitions, argue around the revived dicta, and leverage conflicting circuit authority.

Anne PetersonAnne Peterson
Anne DuttonAnne Dutton
Daniella Prieshoff

Daniella Prieshoff

Tahirih Justice Center

Anne Peterson

Anne Peterson

Center for Gender & Refugee Studies

Anne Dutton

Anne Dutton

Center for Gender & Refugee Studies

Daniella Prieshoff

Daniella Prieshoff

Tahirih Justice Center

Daniella Prieshoff is the Senior Managing Attorney at Tahirih Justice Center’s Maryland office, where she provides trauma-informed counsel and representation to immigrant survivors of gender-based violence. She represents survivors in defensive and affirmative asylum, withholding of removal, relief under the CAT, VAWA cancellation of removal, VAWA petitions, and T and U visa petitions before the immigration courts, the Board of Immigration Appeals, and U.S. Citizenship and Immigration Services. She is adjunct faculty at the University of Baltimore School of Law, teaching trial advocacy, and is a native Spanish speaker.

Education & Credentials

Daniella earned her J.D. from the University of Baltimore Law School in 2012 and her B.A. from the University of Maryland, College Park. She began her legal career in 2012 as judicial law clerk to the Honorable Glenn T. Harrell on the Maryland Supreme Court.

Recognition & Leadership

Daniella serves on the Legal Advisory Council for the HEAL Refugee Health & Asylum Collaborative's Forensic Evaluation Clinic.

Professional Involvement

Daniella is adjunct faculty at the University of Baltimore School of Law, where she teaches trial advocacy.

Experience

Before re-joining Tahirih in 2021, Daniella was a Senior Attorney at Kids in Need of Defense, where she supervised a team of attorneys and a paralegal and advocated for unaccompanied immigrant children in their asylum, Special Immigrant Juvenile Status, and T and U visa petitions. Earlier, she was a Senior Attorney at Tahirih's Baltimore office, advocating for immigrant survivors of gender-based violence in their immigration and domestic relations matters, and a Staff Attorney at Farmworker Legal Services of Michigan, where she represented indigent immigrant farmworkers in immigration and employment cases, initiated an advocacy project to expand representation of workplace sexual assault survivors, and developed a community partners network sensitive to their needs.
Anne Peterson

Anne Peterson

Center for Gender & Refugee Studies

Anne Peterson is Senior Counsel at the Center for Gender & Refugee Studies (“CGRS”), where her work includes advocating for asylum seekers’ rights and protections through strategic litigation and amici support and by providing technical assistance and training to asylum practitioners. Anne has over sixteen years of experience representing clients before the immigration courts, the Board of Immigration Appeals, and the Federal District Courts and Courts of Appeals.

Education & Credentials

Anne earned her J.D. from Golden Gate University School of Law and her B.A. in English/Socio-linguistics from The Evergreen State College. She is admitted to practice in California, Washington, and New York, and before numerous Federal District Courts and Courts of Appeals.

Recognition & Leadership

Anne's litigation advocacy has resulted in several positive precedential decisions. Most recently she was co-counsel in Alfaro-Zelaya v. Bondi, a nexus and Convention Against Torture challenge in a gender-based persecution claim, and O.C.V. v. Garland, which overturned Matter of M-R-M-S-, and was amicus counsel in Tipan Lopez v. U.S. Attorney General, which rejected the BIA's restrictive nexus test.

Professional Involvement

Anne advocates for asylum seekers through strategic litigation and amici support, regulatory analysis and policy advocacy, and developing practice advisories and presenting trainings for advocates. She provides technical assistance to attorneys and focuses on educating and mentoring other attorneys and collaborating to develop case strategies.

Experience

Anne represents clients before the immigration courts, the Board of Immigration Appeals, and the Federal District Courts and Courts of Appeals, with litigation advocacy that has produced several positive precedential decisions. Before law school, she worked as a chef in San Francisco, California, and Seattle, Washington.
Anne Dutton

Anne Dutton

Center for Gender & Refugee Studies

Anne Dutton is Senior Counsel at the Center for Gender & Refugee Studies (“CGRS”), where she engages in strategic litigation on a range of asylum issues and provides technical assistance and training to other attorneys representing asylum seekers. Anne first joined CGRS as an Equal Justice Works Fellow. She is a Spanish speaker.

Education & Credentials

Anne earned her J.D. from the University of Minnesota Law School and her M.S.W. from the University of Minnesota School of Social Work. She received her B.A. in Social Work, magna cum laude, from St. Olaf College. She is admitted to practice in California and Minnesota and clerked for the Honorable Gerard E. Lynch of the Second Circuit.

Recognition & Leadership

At the University of Minnesota Law School, Anne served as Student Director of the Federal Immigration Litigation Clinic and Articles Submission Editor of the University of Minnesota Law Review, graduating magna cum laude.

Professional Involvement

Anne engages in strategic litigation on a range of asylum issues and provides technical assistance and training to other attorneys representing asylum seekers. Prior to law school, she worked for Lutheran Immigration and Refugee Service's policy advocacy office, covering issues related to unaccompanied children, immigration detention, and refugee and asylum law.

Experience

Anne first joined CGRS as an Equal Justice Works Emerson Fellow, where her work focused on advancing children's asylum claims in jurisdictions including Atlanta, Charlotte, and Kansas City, serving as lead counsel on model cases involving child applicants from Central America, monitoring and intervening in key appellate cases, and providing training and technical assistance to pro bono attorneys. Before assuming her Staff Attorney role, she clerked for the Honorable Gerard E. Lynch of the Second Circuit.
Daniella Prieshoff

Daniella Prieshoff

Tahirih Justice Center

Daniella Prieshoff is the Senior Managing Attorney at Tahirih Justice Center’s Maryland office, where she provides trauma-informed counsel and representation to immigrant survivors of gender-based violence. She represents survivors in defensive and affirmative asylum, withholding of removal, relief under the CAT, VAWA cancellation of removal, VAWA petitions, and T and U visa petitions before the immigration courts, the Board of Immigration Appeals, and U.S. Citizenship and Immigration Services. She is adjunct faculty at the University of Baltimore School of Law, teaching trial advocacy, and is a native Spanish speaker.

Education & Credentials

Daniella earned her J.D. from the University of Baltimore Law School in 2012 and her B.A. from the University of Maryland, College Park. She began her legal career in 2012 as judicial law clerk to the Honorable Glenn T. Harrell on the Maryland Supreme Court.

Recognition & Leadership

Daniella serves on the Legal Advisory Council for the HEAL Refugee Health & Asylum Collaborative's Forensic Evaluation Clinic.

Professional Involvement

Daniella is adjunct faculty at the University of Baltimore School of Law, where she teaches trial advocacy.

Experience

Before re-joining Tahirih in 2021, Daniella was a Senior Attorney at Kids in Need of Defense, where she supervised a team of attorneys and a paralegal and advocated for unaccompanied immigrant children in their asylum, Special Immigrant Juvenile Status, and T and U visa petitions. Earlier, she was a Senior Attorney at Tahirih's Baltimore office, advocating for immigrant survivors of gender-based violence in their immigration and domestic relations matters, and a Staff Attorney at Farmworker Legal Services of Michigan, where she represented indigent immigrant farmworkers in immigration and employment cases, initiated an advocacy project to expand representation of workplace sexual assault survivors, and developed a community partners network sensitive to their needs.
Anne Peterson

Anne Peterson

Center for Gender & Refugee Studies

Anne Peterson is Senior Counsel at the Center for Gender & Refugee Studies (“CGRS”), where her work includes advocating for asylum seekers’ rights and protections through strategic litigation and amici support and by providing technical assistance and training to asylum practitioners. Anne has over sixteen years of experience representing clients before the immigration courts, the Board of Immigration Appeals, and the Federal District Courts and Courts of Appeals.

Education & Credentials

Anne earned her J.D. from Golden Gate University School of Law and her B.A. in English/Socio-linguistics from The Evergreen State College. She is admitted to practice in California, Washington, and New York, and before numerous Federal District Courts and Courts of Appeals.

Recognition & Leadership

Anne's litigation advocacy has resulted in several positive precedential decisions. Most recently she was co-counsel in Alfaro-Zelaya v. Bondi, a nexus and Convention Against Torture challenge in a gender-based persecution claim, and O.C.V. v. Garland, which overturned Matter of M-R-M-S-, and was amicus counsel in Tipan Lopez v. U.S. Attorney General, which rejected the BIA's restrictive nexus test.

Professional Involvement

Anne advocates for asylum seekers through strategic litigation and amici support, regulatory analysis and policy advocacy, and developing practice advisories and presenting trainings for advocates. She provides technical assistance to attorneys and focuses on educating and mentoring other attorneys and collaborating to develop case strategies.

Experience

Anne represents clients before the immigration courts, the Board of Immigration Appeals, and the Federal District Courts and Courts of Appeals, with litigation advocacy that has produced several positive precedential decisions. Before law school, she worked as a chef in San Francisco, California, and Seattle, Washington.
Anne Dutton

Anne Dutton

Center for Gender & Refugee Studies

Anne Dutton is Senior Counsel at the Center for Gender & Refugee Studies (“CGRS”), where she engages in strategic litigation on a range of asylum issues and provides technical assistance and training to other attorneys representing asylum seekers. Anne first joined CGRS as an Equal Justice Works Fellow. She is a Spanish speaker.

Education & Credentials

Anne earned her J.D. from the University of Minnesota Law School and her M.S.W. from the University of Minnesota School of Social Work. She received her B.A. in Social Work, magna cum laude, from St. Olaf College. She is admitted to practice in California and Minnesota and clerked for the Honorable Gerard E. Lynch of the Second Circuit.

Recognition & Leadership

At the University of Minnesota Law School, Anne served as Student Director of the Federal Immigration Litigation Clinic and Articles Submission Editor of the University of Minnesota Law Review, graduating magna cum laude.

Professional Involvement

Anne engages in strategic litigation on a range of asylum issues and provides technical assistance and training to other attorneys representing asylum seekers. Prior to law school, she worked for Lutheran Immigration and Refugee Service's policy advocacy office, covering issues related to unaccompanied children, immigration detention, and refugee and asylum law.

Experience

Anne first joined CGRS as an Equal Justice Works Emerson Fellow, where her work focused on advancing children's asylum claims in jurisdictions including Atlanta, Charlotte, and Kansas City, serving as lead counsel on model cases involving child applicants from Central America, monitoring and intervening in key appellate cases, and providing training and technical assistance to pro bono attorneys. Before assuming her Staff Attorney role, she clerked for the Honorable Gerard E. Lynch of the Second Circuit.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.4
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

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MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Approved
Indiana
Approved
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Approved
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs