In Support of Applications for Asylum (Form I-589)
To: Asylum Office, Denver Asylum Office, USCIS
From: Brigzen Aroldo Coronado Lobo, Pro Se
María Dalia Dávila Moreno, Pro Se
Alan David Coronado Dávila, Pro Se
Re: Applications for Asylum — Coronado Lobo / Dávila Moreno Family
Date: May 2026
I. INTRODUCTION AND OVERVIEW OF THE CASE
This memorandum is submitted in support of three related asylum applications filed by members of the same family: Brigzen Aroldo Coronado Lobo (principal applicant, with Kevin David Coronado Dávila included as derivative beneficiary), María Dalia Dávila Moreno (principal applicant), and Alan David Coronado Dávila (principal applicant). All applicants reside at the same address in Bozeman, Montana, and their cases share common factual and legal grounds, while each applicant presents individual circumstances that independently support the grant of asylum.
All four individuals are Venezuelan nationals. None holds any current lawful immigration status in the United States. The Temporary Protected Status (TPS) that covered all four applicants under the 2021 Venezuela TPS designation was terminated on November 7, 2025. None of the applicants has returned to Venezuela since their respective arrivals in the United States. None has filed a prior application for asylum or any other form of immigration protection other than TPS.
The applicants respectfully request that this Office grant asylum to each principal applicant and to the derivative beneficiary included in Mr. Coronado Lobo’s application, on the basis of well-founded fear of persecution on account of political opinion — including imputed political opinion — within the meaning of section 101(a)(42)(A) of the Immigration and Nationality Act (INA).
II. PROCEDURAL BACKGROUND AND APPLICANTS’ PROFILES
A. Brigzen Aroldo Coronado Lobo
Date of Birth: September 18, 1975. Mr. Coronado Lobo entered the United States on February 18, 2017, through John F. Kennedy International Airport in New York, on a B-2 visitor visa. He has resided continuously in the United States since that date. He obtained TPS under the 2021 Venezuela designation, effective August 16, 2022, which was subsequently renewed through September 10, 2025. His TPS terminated on November 7, 2025. He is the father of Alan David Coronado Dávila and Kevin David Coronado Dávila, and the former spouse of María Dalia Dávila Moreno. Kevin David Coronado Dávila is included as a derivative beneficiary in his application.
B. Kevin David Coronado Dávila (Derivative Beneficiary)
Date of Birth: July 30, 2009. Kevin David Coronado Dávila entered the United States on October 4, 2018, through John F. Kennedy International Airport in New York. He is a minor, unmarried, and currently resides with his father in Bozeman, Montana. He has resided continuously in the United States since his arrival and has not returned to Venezuela. He held TPS under the 2021 Venezuela designation, which terminated on November 7, 2025. His inclusion in this application is based on his status as the unmarried minor child of the principal applicant.
C. María Dalia Dávila Moreno
Date of Birth: January 28, 1981. Ms. Dávila Moreno entered the United States on October 4, 2018, through John F. Kennedy International Airport in New York, on a B-2 visitor visa. She arrived with her two sons and has resided continuously in the United States since that date. She obtained TPS under the 2021 Venezuela designation, effective August 15, 2022, which was subsequently renewed through September 10, 2025. Her TPS terminated on November 7, 2025. She is the former spouse of Brigzen Aroldo Coronado Lobo and the mother of Alan David Coronado Dávila and Kevin David Coronado Dávila.
D. Alan David Coronado Dávila
Date of Birth: November 16, 2002. Mr. Alan Coronado Dávila entered the United States on October 4, 2018, through John F. Kennedy International Airport in New York. He was fifteen years old at the time of his arrival. He attended the International High School in New York City and graduated in 2022. He has resided continuously in the United States since his arrival and has not returned to Venezuela. He obtained TPS under the 2021 Venezuela designation, effective August 8, 2022, which was subsequently renewed through September 10, 2025. His TPS terminated on November 7, 2025. His entire adult life has been formed in the United States.
III. LEGAL STANDARD
An applicant for asylum must demonstrate that he or she is a ‘refugee’ within the meaning of INA § 101(a)(42)(A), that is, a person who is unable or unwilling to return to his or her country of nationality because of persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.
The Supreme Court established in INS v. Cardoza-Fonseca, 480 U.S. 421 (1987), that the ‘well-founded fear’ standard requires only that persecution be a reasonable possibility — not that it be more likely than not. An applicant need not demonstrate a probability of persecution, but rather a reasonable fear of it. The Board of Immigration Appeals elaborated on this standard in Matter of Mogharrabi, 19 I&N Dec. 439 (BIA 1987), establishing that a well-founded fear exists when the applicant has a genuine subjective fear of persecution and that fear is objectively reasonable.
Critically, persecution need not be based on the applicant’s actual political opinion — it is sufficient that the persecutor attributes a political opinion to the applicant. Matter of S-P-, 21 I&N Dec. 486 (BIA 1996) established the doctrine of imputed political opinion, under which an applicant may establish eligibility for asylum based on a political opinion attributed to him or her by the persecutor, regardless of whether the applicant actually holds that opinion. The relevant inquiry is not what the applicant believes, but what the persecutor believes or concludes about the applicant.
Where an applicant does not demonstrate past persecution, a well-founded fear of future persecution may nonetheless be established through objective evidence of country conditions and a credible showing that the applicant’s personal profile makes him or her a person of potential interest to the persecutor. Hanna v. Keisler, 471 F.3d 645 (6th Cir. 2006).
IV. TIMELINESS — EXCEPTION FOR CHANGED CIRCUMSTANCES
INA § 208(a)(2)(B) requires that an asylum application be filed within one year of the applicant’s last arrival in the United States, unless the applicant demonstrates either changed circumstances that materially affect eligibility or extraordinary circumstances relating to the delay. 8 C.F.R. § 208.4(a)(4)(i) provides that changed circumstances include changes in applicable U.S. law or activity in the applicant’s country of nationality that materially affect the applicant’s eligibility for asylum.
All three principal applicants entered the United States between 2017 and 2018 — well beyond one year before the date of these applications. However, each applicant qualifies for the changed circumstances exception on the following grounds:
On November 7, 2025, the Department of Homeland Security terminated the 2021 Venezuela TPS designation, eliminating the lawful immigration status that all four applicants had relied upon. This termination constitutes a change in applicable U.S. law that materially affected the applicants’ eligibility for asylum by eliminating the legal basis for their continued presence in the United States and making the prospect of forced return to Venezuela immediate and concrete. Each applicant presents this application within a reasonable period following that termination, consistent with the requirements of 8 C.F.R. § 208.4(a)(4)(ii).
The timeline from the termination of TPS to the filing of these applications reflects a reasonable response to the changed circumstances. Following the termination of TPS in November 2025, the applicants experienced significant disruption, including loss of employment and financial instability. They sought legal counsel in December 2025 but ultimately concluded that the approach being proposed did not accurately reflect their circumstances, and they ended that representation in April 2026. They have prepared and filed these applications promptly thereafter, within six months of the TPS termination that constitutes the changed circumstance.
Additionally, the United States Secretary of State, Marco Rubio, stated publicly in May 2025 — in testimony before the House of Representatives — that Venezuelans who would lose their TPS protection would be entitled to apply for asylum, and that many would have credible applications. This public acknowledgment by the executive branch that TPS termination would trigger asylum applications further supports the reasonableness of the applicants’ response to the changed circumstances.
V. GROUNDS FOR ASYLUM — POLITICAL OPINION AND IMPUTED POLITICAL OPINION
A. The Shared Family Profile
The three principal applicants share a family profile that, in the current political environment in Venezuela, creates an objectively reasonable fear of persecution on account of actual and imputed political opinion. That profile includes the following elements:
- Prolonged residence in the United States: Mr. Coronado Lobo has lived in the United States for more than nine years; Ms. Dávila Moreno and Mr. Alan Coronado Dávila have lived here for more than seven years. During this entire period, none of the applicants returned to Venezuela.
- Temporary Protected Status: All three principal applicants and the derivative beneficiary held TPS granted by the United States government for several years. TPS is a form of American immigration protection that, in the Venezuelan government’s political framework, may be characterized as alignment with or acceptance of benefits from a government Venezuela’s leadership has declared an adversary.
- Family ties to United States citizens and permanent residents: Rodney Coronado Lobo, the brother of Mr. Brigzen Coronado Lobo and the uncle of Mr. Alan Coronado Dávila, had a publicly visible association with government-aligned political organizations in Venezuela and now resides in the United States as a lawful permanent resident, married to a United States citizen, with daughters who are United States citizens. The Venezuelan government has demonstrated a pattern of treating diaspora families with government-adjacent backgrounds as politically unreliable when members relocate to the United States.
- Known political opposition: Mr. Brigzen Coronado Lobo and Ms. Dávila Moreno were each known within their personal and community circles in Venezuela as individuals who opposed the Chavista government. That opposition was expressed openly among family, friends, and acquaintances, and is supported by declarations from individuals who knew them in Venezuela.
- Social media exposure: Ms. Dávila Moreno maintains public social media accounts under her real name on Facebook, Instagram, and TikTok. She interacted with content related to events of January 2026 that the Venezuelan government has characterized as a foreign attack against its territory. This activity is identifiable and creates exposure under the broad language of the Ley Orgánica Libertador Simón Bolívar.
- No operational Venezuelan consular services: None of the applicants can renew their Venezuelan passports from within the United States, as Venezuela does not maintain an operational embassy in this country. This practical barrier to return further underscores their vulnerability as persons who have been unable to maintain normal consular relationships with the Venezuelan state.
B. Alan David Coronado Dávila — Additional Individual Grounds
Mr. Alan Coronado Dávila presents an additional dimension of vulnerability specific to his situation. He arrived in the United States at the age of fifteen and has spent his entire adult life here. He has no practical experience navigating Venezuela as an adult — its security apparatus, its social dynamics, its political pressures, or the daily conduct required to avoid attracting the attention of government-aligned groups. This complete absence of adult experience in Venezuela renders him uniquely vulnerable upon return, as he lacks the practical knowledge that Venezuelan adults develop through years of living under the current regime.
VI. OBJECTIVE EVIDENCE OF COUNTRY CONDITIONS
A. The Legal Framework Established by the Venezuelan Government
The Venezuelan government has enacted legislation and issued decrees that formalize the persecution of individuals perceived as connected to foreign interests or opposed to governmental authority. These legal instruments establish that the applicants’ fear is objectively reasonable — not speculative.
The Ley Orgánica Libertador Simón Bolívar contra el Bloqueo Imperialista y en Defensa de la República Bolivariana de Venezuela (Organic Law Libertador Simón Bolívar against the Imperialist Blockade and in Defense of the Bolivarian Republic of Venezuela), enacted by the Venezuelan National Assembly and published in Official Gazette No. 6,859 Extraordinary on November 29, 2024, criminalizes with prison sentences of twenty-five to thirty years any conduct the government characterizes as promoting, supporting, facilitating, or favoring international sanctions, foreign measures, or actions against Venezuela’s sovereignty. Article 7 defines prohibited conduct broadly, including collaboration with foreign officials or organizations directed at the imposition of coercive measures. Article 11 establishes the criminal penalties. Article 21 specifically sanctions the dissemination through electronic media and social networks of content the government characterizes as promoting restrictive measures against Venezuela. Article 23 creates a National Registry of suspected individuals, with immediate administrative consequences including asset freezes and prohibition of entry into Venezuela.
The breadth of this legislation is deliberately expansive. It does not require proof of material participation in sanctions or foreign policy decisions. It reaches perceived sympathy, indirect support, or conduct the government interprets as favorable to foreign interests — including social media activity. For individuals with the applicants’ profile, this law creates a formal legal basis for investigation, registration, and prosecution.
On January 3, 2026, the Venezuelan government published Decree No. 5,200 in Official Gazette No. 6,954 Extraordinary, declaring a State of External Commotion across the entire national territory. Article 5 of the decree ordered the immediate nationwide search and capture of any person involved in the promotion or support of what the government characterized as a United States armed attack against Venezuela — a reference to the events surrounding the capture of Nicolás Maduro on that date. Reuters reported on January 5, 2026, that the decree ordered police to ‘immediately begin the national search and capture of everyone involved in the promotion or support for the armed attack by the United States.’ The scope of that mandate — encompassing promotion and support, not only direct participation — demonstrates the expansive reach of the government’s enforcement posture in the current political environment.
B. Documented Country Conditions
The following sources document the conditions in Venezuela that corroborate the applicants’ fear:
The United States Department of State issued a Venezuela Travel Advisory (updated March 19, 2026, last updated April 20, 2026) classifying Venezuela at Level 3 — Reconsider Travel — with specific regions classified at Level 4 — Do Not Travel. The advisory cites risk of crime, kidnapping, terrorism, and poor health infrastructure. The advisory notes that irregular armed groups carry out acts of violence without warning, and that U.S. government employees require special authorization to travel to Venezuela due to safety risks. This official U.S. government assessment corroborates the objective dangerousness of Venezuela for returning individuals.
Freedom House documented in its report ‘Venezuelan Transnational Repression’ (November 13, 2025) that the Maduro regime has a documented track record of extraterritorial violence against Venezuelan exiles. Chilean investigators concluded that Venezuelan authorities orchestrated the February 2024 murder in Santiago of former Venezuelan military officer Ronald Ojeda, with the assistance of organized criminal networks. In Colombia, an attack was carried out in October 2025 against Venezuelan human rights defenders Yendri Velásquez and Luis Peche, who had fled Venezuela amid increasing persecution. Freedom House documented that the regime uses Interpol notices, passport cancellations, and online harassment as additional tools of transnational repression.
Freedom House also documented in ‘When Exile is Another Tool of Authoritarianism’ (October 10, 2024) that the Venezuelan government routinely cancels the passports of dissidents and journalists without explanation, and that Venezuela has withdrawn consular services from nationals abroad by recalling diplomatic staff from multiple countries in response to political criticism. The Inter-American Commission on Human Rights documented 36 instances of passports being revoked. This pattern directly corroborates the applicants’ inability to renew their Venezuelan passports from the United States.
The Washington Office on Latin America (WOLA) reported in August 2024 that following the July 28 presidential elections, the Venezuelan government detained more than 1,350 people arbitrarily, killed at least 25 demonstrators, and targeted human rights defenders, activists, and lawyers. WOLA, along with 24 other human rights organizations, condemned these acts as systematic repression. The Inter-American Commission on Human Rights characterized these practices as state-sponsored terrorism. WOLA further reported in February 2025 that the termination of TPS for approximately 700,000 Venezuelans risks deportation of individuals directly into the hands of an authoritarian regime.
The Independent International Fact-Finding Mission on Venezuela, established by the United Nations Human Rights Council, documented in its September 2025 report that Venezuelan authorities have committed crimes against humanity, including arbitrary detention, torture, and enforced disappearances, as part of a systematic attack against persons perceived as political opponents or dissidents. This finding by an independent UN body provides the highest level of international corroboration of the Venezuelan government’s systematic use of persecution as a tool of political control.
VII. INABILITY TO SEEK PROTECTION IN VENEZUELA
The Venezuelan government is the source of the persecution the applicants fear. There is no functioning independent judiciary in Venezuela capable of providing protection from state persecution. The Supreme Court of Justice operates as an instrument of the executive branch. Civil society organizations, independent media, and human rights defenders have been systematically dismantled, exiled, or silenced. The government’s own security apparatus — including the SEBIN (Servicio Bolivariano de Inteligencia Nacional), which functions as the political police and has been documented as engaging in arbitrary detention and torture, and the DGCIM (Dirección General de Contrainteligencia Militar), the military counterintelligence body responsible for internal surveillance and repression — operates throughout the entire national territory. Internal relocation within Venezuela would not protect any of the applicants from a government with the means and motivation to identify and act against individuals with their profile.
VIII. EVIDENCE SUBMITTED
The following documents are submitted in support of these applications:
Personal Declarations
- Declaration of Brigzen Aroldo Coronado Lobo
- Declaration of Alan David Coronado Dávila
- Declaration of María Dalia Dávila Moreno
Immigration Documents
- Form I-797 — TPS Approval Notices for all applicants (multiple)
- Form I-94 — Arrival/Departure Records for all applicants
- Passports — Brigzen Aroldo Coronado Lobo, María Dalia Dávila Moreno, Alan David Coronado Dávila, Kevin David Coronado Dávila
Identity and Family Documents
- Birth certificates with certified translations — all applicants
- Divorce certificate / marriage documentation — Brigzen Aroldo Coronado Lobo and María Dalia Dávila Moreno
Venezuelan Legal Framework
- Ley Orgánica Libertador Simón Bolívar contra el Bloqueo Imperialista y en Defensa de la República Bolivariana de Venezuela — Gaceta Oficial No. 6,859 Extraordinario, November 29, 2024 (original in Spanish with translation)
- Decreto No. 5,200 mediante el cual se declara el Estado de Conmoción Exterior en todo el Territorio Nacional — Gaceta Oficial No. 6,954 Extraordinario, January 3, 2026 (original in Spanish with translation)
Country Conditions Evidence
- U.S. Department of State — Venezuela Travel Advisory, Level 3 (updated March 19, 2026; last updated April 20, 2026)
- Reuters — ‘Venezuela orders police to find, arrest anyone involved in supporting U.S. attack-decree’ (January 5, 2026)
- Freedom House — ‘TNR Watch: Venezuelan Transnational Repression’ (November 13, 2025)
- Freedom House — ‘TNR Watch: When Exile is Another Tool of Authoritarianism’ (October 10, 2024)
- Washington Office on Latin America (WOLA) — ‘Venezuela: We Condemn the Systematic Repression by the Government Against Human Rights Defenders and Demonstrators’ (August 14, 2024)
- Washington Office on Latin America (WOLA) — ‘By Terminating Legal Pathways, the U.S. Is Abandoning Venezuelans’ (February 14, 2025)
- Washington Office on Latin America (WOLA) — Human Rights in Venezuela: Crisis Response
- Independent International Fact-Finding Mission on Venezuela — Conclusions (September 2025)
- Marco Rubio, U.S. Secretary of State — Statement on Venezuelan asylum applicants (May 21, 2025), as reported by EFE / De Último Minuto
IX. CONCLUSION
The applicants — Brigzen Aroldo Coronado Lobo, María Dalia Dávila Moreno, Alan David Coronado Dávila, and Kevin David Coronado Dávila as derivative beneficiary — each present a well-founded fear of persecution on account of political opinion, including imputed political opinion, within the meaning of INA § 101(a)(42)(A). Their fear is both subjectively genuine and objectively reasonable, grounded in their individual profiles and corroborated by the formal legal mechanisms the Venezuelan government has established to investigate, register, and prosecute individuals it perceives as connected to foreign interests or opposed to its authority.
Venezuela’s own legislative and executive acts — the Ley Simón Bolívar and Decree No. 5,200 — create the legal basis for the persecution the applicants fear. The documented track record of the Venezuelan government in pursuing dissidents and perceived opponents, both within Venezuela and transnationally, demonstrates that this fear is not speculative. The United States Department of State, Freedom House, the Washington Office on Latin America, and the United Nations’ own fact-finding mission have each independently documented conditions in Venezuela that corroborate the objective basis for the applicants’ fear.
For these reasons, the applicants respectfully request that this Office grant asylum to Brigzen Aroldo Coronado Lobo and Kevin David Coronado Dávila (derivative), to María Dalia Dávila Moreno, and to Alan David Coronado Dávila.
Respectfully submitted,
_______________________________________
Brigzen Aroldo Coronado Lobo
Pro Se Applicant
Bozeman, Montana
May 2026