Cir.2000) (collecting cases), and where death threats are combined with physical violence or displays of imminent force, a petitioner is even more likely to be able to establish past persecution. See, e.g., Ruano v. Ashcroft, 301 F.3d 1155, 1160 (9th Cir.2002) (finding past persecution where petitioner was threatened by men who had “closely confronted” him and drawn their pistols in his presence). Thus, Singh’s statement that the KLF members held a gun to his head when they threatened him was a particularly important aspect of his claim to consider in assessing whether he had experienced past persecution. Second, applicants can establish past persecution when threats are coupled with harm to people close to the applicant. See, e.g., Khup v. Ashcroft, 376 F.3d 898, 904 (9th Cir.2004) (<HOLDING>). Therefore, the BIA should have considered the
holding that a showing of past persecution creates a rebuttable presumption of future persecution holding that harassment threats and one beating did not constitute persecution holding that threats combined with the murder of a fellow preacher constituted past persecution holding that threats standing alone generally do not constitute past persecution holding that threats standing alone  constitute past persecution in only a small category of cases and only when the threats are so menacing as to cause significant actual suffering or harm 