Negusie v. Holder

Summary

The Court held that the agency and the Court of Appeals improperly treated prior precedent as requiring the persecutor bar to apply categorically to coerced assistance in persecution. Because the statute is ambiguous on whether coercion or duress matters, the agency must interpret the statute in the first instance without relying on that mistaken premise, and the judgment was reversed and remanded. Justice Thomas, dissenting, would have held that the statute unambiguously excludes any voluntariness exception; Justice Stevens, joined by Justice Breyer, would have resolved the statutory question in favor of a duress exception before remanding; and Justice Scalia, joined by Justice Alito, agreed with remand but would permit the agency to retain its existing rule if reasonably justified.