Confusion & obfuscation
We do not believe that the government is using particularity to impose a numerical or size limitation on the meaning of “particular social group.” However, we are hardpressed to discern any difference between the requirement of “particularity” and the discredited requirement of “social visibility.” Indeed, they appear to be different articulations of the same concept and the government’s attempt to distinguish the two oscillates between confusion and obfuscation, while at times both confusing and obfuscating.
–from Valdiviezo-Galdamez v. AG of the United States, 663 F.3d 582 (3d Cir. 2011), a Third Circuit decision granting a Honduran asylum seeker’s petition for review of his asylum and withholding of removal (i.e. deportation) applications previously denied by the Board of Immigration Appeals; emphasis added
To paraphrase the late Gil Scott-Heron, why do you need the Board of Immigration Appeals for confusion and obfuscation? Two old winos can confuse & obfuscate you just as well …