Emory International Law Review


In 2001, Albanian Johana Cece fled her hometown of Korçë, near Albania's Greek border. Cece was the victim of attempted sex trafficking by a local gang member notorious for kidnapping young Albanian women and forcing them into prostitution. Ultimately, Cece sought refuge in the United States and applied for asylum. Returning to Albania meant returning to the threat of sex trafficking. In 2013, the Seventh Circuit found that Cece was eligible for asylum because she proffered a 'particular social group' (PSG) cognizable under 8 U.S.C. § 1101(a)(42)(A). In 2005 and 2009, the Sixth Circuit held that women threatened with sex trafficking in their home countries were not eligible for American asylum on grounds of insufficient PSG proffers. Emily Niklaus Davis argues that the Seventh Circuit's interpretation of PSG proffers by those facing the threat of sex trafficking is superior to the prior interpretations of the Sixth Circuit.