"[A] single attempt to report an incident of harm by private actors to local police, without further harm from the police themselves or evidence of their widespread collusion with alleged persecutors, does not establish that the government, as a whole, is unable or unwilling to protect a respondent from persecution." Matter of K-S-H-, 29 I&N Dec. 307, 310 (BIA 2025).

"Any analysis of conduct rising to the level of persecution requires the consideration of 'the cumulative effect of the allegedly persecutory incidents.'" Matter of E-M-F-S-, 29 I&N Dec. 379, 383-84 (BIA 2025) (quoting De Santamaria v. U.S. Att'y Gen., 525 F.3d 999, 1008 (11th Cir. 2008)).

Revealed: 46m displaced people excluded from Covid jab programmes | Coronavirus | The Guardian. (n.d.). Retrieved May 12, 2021, from https://www.theguardian.com/world/2021/may/07/at-least-46m-displaced-people-excluded-from-covid-jabs-who-study-shows

Zocchi, B. (2020-04-30). What coronavirus looks like at the Bosnian-Croatian frontier for Europe’s unwanted migrants. The Conversation. http://theconversation.com/what-coronavirus-looks-like-at-the-bosnian-croatian-frontier-for-europes-unwanted-migrants-137226