In a legal brief filed by DHS in an asylum case in April 2009, the Obama administration has now stated a clear, though narrow, basis upon which victims of domestic violence may seek asylum. This new position resolves years of legal battles during which domestic violence was not recognized by the U.S. government as a basis for asylum. To permit victims of domestic violence to demonstrate a well-founded fear of persecution because of their membership in a particular social group, DHS has now set forth alternate formulations of the term “particular social group.” Victims of abuse may be eligible for asylum if they can show that they are treated by their abuser like property and their home country widely tolerates domestic abuse. Victims must show that they could not obtain protection through their home country’s institutions or by moving to another part of the country.