The following excerpt is from Sarvia-Quintanilla v. U.S. I.N.S., 767 F.2d 1387 (9th Cir. 1985):
The phrase "well-founded fear of persecution" has not been precisely defined; the extent of its "generosity" and "liberality" is unclear. See Bolanos-Hernandez v. INS, 749 F.2d at 1321 (disposing of the case under only the "clear probability" standard); Zavalla-Bonilla v. INS, 730 F.2d 562, 564 n. 1 (9th Cir.1984) (declining to reach the issue of the meaning of "well-founded" fear). It is clear, however, that a proper evaluation of a section 208(a) application must include "consideration of the
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