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Political Asylum For Whistleblowers

Starting in 2000, U.S. courts recognized that whistleblowing against government corruption could be grounds for political asylum in the United States.  The landmark case on this issue, Grava v. INS, 205 F.3d 1177 (9th Cir. 2000) held as follows: “Whistleblowing against one’s supervisors at work is not, as a matter of law, always an exercise of political opinion.  However, where the whistle blows against corrupt government officials, it may constitute political activity sufficient to form the basis of persecution…”

Following are examples of cases in which the petitioner alien sought judicial review of the Board of Immigration Appeals' decision to deny asylum.  In each of these cases the petition for review was granted. 


Haxhiu v. Mukasey, 519 F.3d 685 (7th Cir. 2008)


Mamouzian v. Ashcroft, 390 F.3d 1129 (9th Cir. 2004)

Aleksanyan v. Gonzales, 246 Fed. Appx. 471 (9th Cir. 2007)

Hayrapetyan v. Mukasey, 534 F.3d 1330 (10th Cir. 2008)

Aroyan v. Gonzales, 183 Fed. Appx. 634 (9th Cir. 2006)

Harutyunyan v. Ashcroft, 104 Fed. Appx. 86 (9th Cir. 2004)

Pashalyan v. Gonzases, 185 Fed. Appx. 603 (9th Cir. 2006)

Gyumushyan v. Holder (9th Cir. 2009)


Hasan v. Ashcroft, 380 F.3d 1114 (9th Cir. 2004)


Bu v. Gonzales, 490 F.3d 424 (6th Cir. 2007)

Cao v. Attorney General, 407 F.3d 146 (3rd Cir. 2005)

Zhu v. Mukasey, 537 F.3d 1034 (9th Cir. 2008)

Wang v. Mukasey, 259 Fed. Appx. 763 (6th Cir. 2008)

Wang v. Gonzales, 163 Fed. Appx. 489 (9th Cir. 2006)

Xiao v. Ashcroft, 98 Fed. Appx. 632 (9th Cir. 2004)


Maldonado-Castro; Mejia-Almendarez v. Ashcroft, 103 Fed. Appx. 113 (9th Cir. 2004)


Nandha v. Gonzales, 207 Fed. Appx. 875 (9th Cir. 2006)

Singh v. Gonzales, 180 Fed. Appx. 747 (9th Cir. 2006) 


Massetti v. Gonzales, 151 Fed. Appx. 519 (9th Cir. 2005)


Grava v. Immigration and Naturalization Service, 205 F.3d 1177 (9th Cir. 2000)


Glistina v. Mukasey, 284 Fed. Appx. 429 (9th Cir. 2008)


Morozov v. Mukasey, 258 Fed. Appx. 138 (9th Cir. 2007)

Fedunyak v. Gonzales, 477 F.3d 1126 (9th Cir. 2007)

Sagaydak v. Gonzales, 405 F.3d 1035 (9th Cir. 2005)


Mansurjonov v. Gonzales, 241 Fed Appx. 443 (9th Cir. 2007)


Important Notice:

These case links are provided for informational purposes only.  The National Whistleblowers Center has not undertaken an independent evaluation of the cases linked on this page.  The NWC does not provide legal advice nor is it staffed with experts on international law.  However, before filing a claim it is highly recommended that you contact an attorney.  If you have issue concerning an American company or law, the attorney referral service may be able to help you. 

Please email if you have any cases you would like to see added.