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CA9 on Venue, Social Group, CAT, Mexico, Cartels: Plancarte Sauceda v. Garland

August 21, 2021 (1 min read)

Plancante Sauceda v. Garland

"We first address venue and hold that the Ninth Circuit is the proper venue for this petition for review because Boise, Idaho, is the place “in which the immigration judge completed the proceedings.” See 8 U.S.C. § 1252(b)(2). We next address the substance of Plancarte’s petition and hold that (1) the BIA’s rejection of the proposed particular social group of “female nurses” on the ground that “nursing” is not an immutable characteristic was unreasonable, and (2) the BIA’s CAT finding that there was no governmental involvement or acquiescence in the cartel’s actions is not supported by substantial evidence. We grant the petition and remand to the BIA."

[Hats way off to Vallerye Anderson!]