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https://www.courtlistener.com/opinion/2614/bah-v-mukasey/?q=threats rise to level of persecution&type=o&order_by=score desc&stat_Precedential=on&court=scotus ca2 bia
The Persecution can be a one-time event or something that can only happen once. It does not need to be repeated or ongoing harm. They cite to YTL and the China one-child policy in support of this.
In re Y-T-L-, 23 I. & N. Dec. 601 (B.I.A.2003) (en banc), the BIA, assessing the asylum application of an applicant fleeing China due to its "one child" policy, held that even though forced sterilization was an act of persecution that would not be repeated, the fact that the act had occurred in the past could not in and of itself be used to rebut the presumption of a fear of future persecution because forced sterilization, unlike most other forms of persecution, constituted continuing persecution. Id. at 605. I conclude that the BIA erred in failing to treat female genital mutilation in the same manner, but in order to more fully explain my reasoning, some background as to the evolution of the assessment of forced sterilization claims is necessary.