812, 117 L.Ed.2d 38 (1992). In essence, petitioner asserts that the IJ erroneously interpreted the “refu gee” definition by inserting an extra element that is not found in the statute. She refers to the IJ’s finding that the petitioner did not qualify as a refugee under § 101(a)(42)(A) of the INA, asserting that the IJ added the element of physical harm, which is neither found in the statute nor the ease law. We are aware that since Congress amended the definition of “refugee” in 1996 to include persons who are subject to, or opponents of, coercion of population control programs, federal courts have taken the difficult task of determining which types of resistance to such programs merit protection through refugee status. See, e.g. Liu v. Ashcroft, 356 F.3d 1153 (9th Cir.2004)(en banc) (<HOLDING>). This case presents a scenario where a woman
holding that the defendant was not entitled to a lesserincluded firstdegree manslaughter instruction when his attorney was forced to concede at oral argument that no evidence supported the adequate provocation element holding that a woman was not entitled to an eed instruction after she murdered five individuals without a recent aggravating incident despite the fact that the woman had suffered significant  physical and emotional harm as a child and abused drugs and alcohol holding woman who alleged she was terminated for having an abortion stated a prima facie case for discrimination holding that a teacher was qualified for unemploymentcompensation benefits when she made bona fide efforts to pass a certification exam and the evidence showed that she took the exam several times and used study aids holding that a woman who was threatened and forced to undergo a gynecological exam but was not sterilized or forced to have an abortion was still entitled to refugee status