Mazariegos-Rodas v. Garland "The Petitioners’ arguments regarding due-process and the “Guatemalan female children without parental protection” PSG were not raised before the BIA and are thus unreviewable, but the BIA’s no-nexus determination...
Matter of D-M-R-, Nov. 15, 2024 Hats off to Dr. Alicia Triche !
Mazariegos-Rodas v. Garland "Beky Izamar Mazariegos-Rodas and Engly Yeraicy Mazariegos-Rodas (collectively, the Petitioners) are two sisters who are natives and citizens of Guatemala. The Petitioners, who were left behind in Guatemala as young children after...
Ferreira v. Garland "Pamlar Ferreira petitions for review of a decision by the Board of Immigration Appeals ("BIA") upholding the denial of her application for withholding of removal. Ferreira requests that we remand the case so that the BIA may...
Vasquez-Rivera v. Garland "Here, the BIA attributed analysis to the IJ that the IJ never undertook. Finding that none of Vasquez-Rivera’s proposed social groups were cognizable, the IJ concluded that her asylum claims failed. With respect to Vasquez...
Here is the Nov. 9, 2023 CA1 decision at issue, 86 F.4th 443. Here is the Round Table's Amicus Brief. Nutshell: "We write to provide the Court with additional context regarding the importance of the IJ’s duty to adequately develop the record as...
Matter of F-C-S- "Regarding the respondent’s two remaining proposed particular social groups, we will remand to the Immigration Judge for further development of the record. The Immigration Judge’s decision contains conflicting legal conclusions...
Espinoza-Ochoa v. Garland "Here, the IJ and BIA found, and the government does not dispute, that Espinoza-Ochoa credibly testified that he experienced harm and threats of harm in Guatemala that "constitute[d] persecution." But the agency concluded...
Sebastian-Sebastian v. Garland "[T]he Board found that Sebastian-Sebastian failed to demonstrate a nexus between her particular social groups and the harm she faced. In its denial of CAT protection, the Board found that Sebastian-Sebastian failed to demonstrate...
Matter of M-R-M-S-, 28 I&N Dec. 757 (BIA 2023) - If a persecutor is targeting members of a certain family as a means of achieving some other ultimate goal unrelated to the protected ground, family membership is incidental or subordinate to that other ultimate...
Avila v. Atty. Gen. "Avila argues that the BIA failed to consider whether Avila’s particular social group (PSG) was cognizable in light of the specific country conditions in Honduras. We agree and will grant Avila’s petition for reconsideration...
Turcios-Flores v. Garland "Under the correct analysis, the record here compels a conclusion that Honduran rural landownership in this case is a common fundamental characteristic because Turcios-Flores should not be required to change this aspect of her identity...
Cristobal Antonio v. Garland "Rebeca Cristobal Antonio, a native and citizen of Guatemala, petitions for review of the Board of Immigration Appeals’ (“BIA”) streamlined affirmance of the immigration judge’s (“IJ”) denial of her claims for asylum, withholding...
Bimpong* v. Garland "Bimpong argues that the BIA erred in concluding that he failed to establish that his membership in a particular social group (“PSG”) is a nexus for the persecution he fears— as is required to qualify for asylum or withholding of removal...
Hats off to Prof. Hiroko Kusuda for her victory in New Orleans Immigration Court ! IJ Eric Marsteller distinguished Jaco v. Garland, stating: "The Fifth Circuit in Jaco v. Garland suggested that "Honduran women" is not sufficiently particular. 16...