Immigration Review

Ep. 238 - Precedential Decisions from 11/11/2024 - 11/17/2024 (nexus to political opinion; church leaders; small business owners; death threats, extortion & past persecution; reasonable relocation; gang violence; unable or unwilling to protect)

Aleman Belloso v. Garland, No. 23-114 (9th Cir. Nov. 13, 2024)

  • nexus; church leader; political opinion; particular social group - influential church leaders; no requirement to report harm for CAT; circularity not fatal; agency misconstruing PSG; no need to report government harm; FMLN; El Salvador

 


Manuel-Soto v. Att'y Gen. U.S., No. 24-1089 (3d Cir. Nov. 12, 2024)

  • small business owners; particularity; immutability; police investigation and unable or unwilling; Guatemala

 


Urias-Orellana v. Garland, No. 24-1042 (1st Cir. Nov. 14, 2024)

  • death threats, extortion, and past persecution; reasonable relocation; failure to report and government acquiescence; country condition reports; El Salvador

 


Cortez-Mejia v. Garland, No. 23-1717 (1st Cir. Nov. 15, 2024)

  • generalized fear of gang violence; 18th Street Gang recruitment against MS-13; death threats; El Salvador

 


Medina-Suguilanda v. Garland, No. 23-2031 (1st Cir. Nov. 14, 2024)

  • unable or unwilling to protect; failure to report to police because of risk of danger; domestic violence; mixed question of law and fact; Ecuador



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