The Board of Immigration Appeals (BIA) held in Matter of C-T-L, 25 I&N Dec. 341 (BIA 2010):
The “one central reason” standard that applies to asylum applications pursuant to section 208(b)(1)(B)(i) of the Immigration and Nationality Act, 8 U.S.C. § 1158(b)(1)(B)(i) (2006), also applies to applications for withholding of removal under section 241(b)(3)(A) of the Act, 8 U.S.C. § 1231(b)(3)(A) (2006).
The "mixed-motive" concept still lives on despite this holding requiring one central reason.
Ricky Malik, Esq.