Ananeh-Firempong v. INS

In Ananeh-Firempong v. I.N.S., 766 F.2d 621 (1st Cir.1985), the petitioner was a member of three small, distinct social groups, including the group of former government party officials who were ousted from power. Ananeh-Firempong, 766 F.2d at 623. Petitioner there provided extensive evidence of killings and explicit death threats against these groups. She also alleged that her family had been severely beaten, placed under house arrest, and had their bank accounts seized. Id. at 623. In Ananeh-Firempong, the Court decided only that the petitioner had made out a prima facie case for withholding of deportation and should have the opportunity to prove the alleged facts in a hearing. Id. at 622. In Ananeh-Firempong v. INS, 766 F.2d 621, 626 (1st Cir.1985), the First Circuit regarded persecution by Ghana authorities of a particular tribe, those associated with the former government, and professionals, business people, and those who were highly educated as persecution of a "social group" within the meaning of 8 U.S.C. Sec. 1253(h). The court held these were "characteristics that are essentially beyond the petitioner's power to change." Id