The following excerpt is from Hussain v. Rosen, 985 F.3d 634 (9th Cir. 2021):
To meet the burden for asylum because of past persecution, the petitioner "has the burden of establishing that (1) his treatment rises to the level of persecution; (2) the persecution was on account of one or more protected grounds; and (3) the persecution was committed by the government, or by forces that the government was unable or unwilling to control." Baghdasaryan v. Holder , 592 F.3d 1018, 1023 (9th Cir. 2010). A petitioner who cannot show past persecution might nevertheless be eligible for relief if he instead shows a
[985 F.3d 646]
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