Does a victim of physical abuse need to report it to the government authorities to establish the government's inability or unwillingness to protect him?

MultiRegion, United States of America

The following excerpt is from Bringas-Rodriguez v. Sessions, 850 F.3d 1051 (9th Cir. 2017):

We have similarly long held that a victim of abuse need not report it to government authorities to establish the government's inability or unwillingness to protect him. In Korablina v. INS , 158 F.3d 1038 (9th Cir. 1998), the petitioner, a Jewish native of Russia and citizen of the Ukraine, was the victim of harassment and beatings perpetrated against Jewish citizens. Id. at 104142. Korablina was fired from the job she had held for twenty-eight years by a new boss who was a member of an ultra-nationalist and anti-Semitic group. Id. at 1041. After searching for six months for a new job, she found work as a clerical secretary to a Jewish man. Id. at 1042. In that new position, she saw three men attack her boss and thereafter return monthly to the office to extort money. Id. Though she and her fellow employees reported the beating to the police, the officers never appeared, and when Korablina sought help from a friend at the municipal city hall, the friend disappeared. Id. Korablina then began receiving anti-Semitic death threats that warned of retaliation if she reported the threats to anyone. Id. Soon thereafter, two men violently attacked Korablina and left her barely breathing, telling her she "could not ... conceal her Jewish origin." Id.

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