BRIEF OF AMICUS CURIAE UNITED NATIONS HIGH COMMISSIONER FOR REFUGEES IN SUPPORT OF PLAINTIFFS-APPELLEES in the case GRACE, et al., Plaintiffs-Appellees, v. WILLIAM P. BARR, ATTORNEY GENERAL, et al., Defendants-Appellants.

I. The United States Is Bound by the 1951 Convention and Its 1967 Protocol Relating to the Status of Refugees II. As Recognized By U.S. and Foreign Courts, UNHCR Provides Authoritative Guidance in Evaluating Claims of Persecution by Non-State Actors III. Violence by Non-State Actors, and in Particular, Domestic and Gang Violence, Can Form the Basis for Asylum A. Matter of A-B- and the New Policies Erroneously State That Domestic and Gang Violence Claims Do Not Meet the “Unable or Unwilling” Standard B. Matter of A-B- and the New Policies Err in Their Interpretation of the “Particular Social Group” Basis for Asylum