¹ See Immigration and Refugee Board, Guidelines Issued by the Chairperson Pursuant to Section 65(3) of the Immigration Act: Women Claimants Fearing Gender-Related Persecution (1993).

² In June, 1996, the Board of Immigration Appeals issued its first precedent decision granting political asylum to a woman seeking to avoid female genital mutilation. In that case, the Board found that the imposition of FGM, constitutes persecution that and the applicant's fear of persecution was based on her membership in a particular social group comprised of “young women of the Tchamba-Kunsuntu Tribe who have not had FGM, as practiced by that tribe, and who oppose the practice.” See Matter of Kasinga, Int. Dec. 3278 (BIA 1996).

³ See Phyllis Coven, Considerations For Asylum Officers Adjudicating Asylum Claims From Women (1996).

⁴ The first circuit court decision to specifically recognize feminism as a political opinion was Fatin y JNS, 12 F.3d 1233, 1242 (3d Cir. 1993) (finding “little doubt that feminism qualifies as a political opinion within the meaning of the relevant statutes.”). See also Lazo-Majano y INS (finding that a woman fleeing rape and other abuse at the hands of a Salvadoran military officer was, through her flight, expressing a political opinion).