This 2004 draft of a Convention Against Torture (CAT) asylum brief is for a youth, a former Honduran gang member who feared death squads, the police and gangs if returned to his home country. The brief argues that he is eligible for a discretionry grant of asylum or, alternatively, the withholding of removal from the United States. The fact that he was previously tortured by a gang, evidence of human rights abuses against children in Honduras, public officials and others executing citizens with government acquiescence, and the government’s failure to protect them are stated as reasons to support his case. This brief should be used for reference only, as case law and citations may have changed.
