In the case of Marlon McDougall v. Pamela Bondi (231722.P.pdf ) the 4th Cirrcuit Court of Appeal found that the BIA and the immigration judge did not properly consider proffered evidence of harm rendered to black persons in Guyana who suffer from mental health issues and lack support in the country if they are deported on the based basis of past criminal behavior, ie. as a criminal deportee. The extensive evidence submitted on behalf of the appellee was not considered and the threat of harm by members of the public overlooked despite the judge’s determination that police would not directly attack him due to his mental and social status. This decision underlines the need to provide extensive evidence of social conditions where a deported person will suffer harm based on his status.