Barry was denied asylum as a direct result of the Board of Immigration Appeals decision in Matter of A-T-, where the court held that past FGM/C alone cannot provide a basis for a fear of future persecution, and Matter of A-K-, where the court held that a parent cannot receive derivative asylum to protect a United States citizen child from FGM/C.
The Board of Immigration Appeals denied Barry's asylum claim based on two court decisions: Matter of A-T- where the court ruled that past FGM/C alone is not enough to establish future persecution, and Matter of A-K- which stated that parents cannot receive asylum for their U.S. citizen children who are at risk from FGM/C.