Fakhry
Fakhry v. Mukasey
Opinion
Opinion
BACKGROUND
I.
Fakhry is from a region in the south of Senegal called Casamance. For decades, Casamance has been torn by fight- ing between the government and an armed opposition group seeking independence for Casamance, the Mouvement des forces démocratiques de Casamance (“MFDC”). Human rights abuses committed by the Senegalese government in this conflict are well-documented. In 1998, for example, it was reported to be “regular practice for the Senegalese army to torture and execute people in Casamance.” See Amnesty International, Senegal: Climate of Terror in Casamance, at 1 (1998) (internal quotations omitted).1 Conditions improved 1 All cited reports are in the certified administrative record. FAKHRY v. MUKASEY 4901 somewhat after a change in government in 2000, but problems in Casamance continue, including “extrajudicial killings” by government forces. See United States Department of State, Senegal, Country Reports on Human Rights Practices — 2002 (2003); see also Ndom v. Ashcroft, 384 F.3d 743, 747-48 (9th Cir. 2004) (describing history of the MFDC and human rights abuses committed by the Senegalese government).