What is the current state of the law on discrimination against a particular social group?

"If past persecution is established, a rebuttable presumption of a well-founded fear arises, 8 C.F.R. 208.13(b)(1), and the burden shifts to the government to demonstrate that there has been a fundamental change in circumstances such that the applicant no longer has a well-founded fear." Tawadrus v. Ashcroft, 364 F.3d 1099, 1103 (9th Cir. 2004) (internal quotation marks omitted).

The term "particular social group" is ambiguous. Donchev v. Mukasey, 553 F.3d 1206, 1215 (9th Cir. 2009).

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