in construing Fedorenko to prohibit recognition of a duress exception to the persecutor bar applicable to §§ 1158(b)(2)(A)© and 1231(b)(3)(B)©. In Negusie, an alien who was himself physically abused by Eritrean officials, before and after being forcibly conscripted into the Eritrean army, was denied asylum based on his actions guarding prisoners themselves subject to persecution on a protected ground. See Negusie v. Holder, 555 U.S. at 522-23, 129 S.Ct. 1159. In vacating, the Supreme Court explained that the Displaced Persons Act at issue in Fedorenko differed from the Refugee Act in structure, language, and purpose, rendering Fedorenko’s, categorical rejection of a voluntariness exception in the former context not necessarily applicable in the latter. See id. at 522,129 S.Ct. 1159 (<HOLDING>). Accordingly, the Court remanded Negusie’s
holding that bia is not bound to apply the fedorenko rule that motive and intent are irrelevant to the persecutor bar  under  1158b2ai and  1231b3bi  holding that the rule does not apply to bar tort claims against service providers holding that procedural bar rule does not apply to ineffectiveness claims holding that the bia rule is unreasonable in this context holding that the bia rule is reasonable