Guzman v. Blanche

Summary

The First Circuit denied Lesvi Lucia Monzon Guzman's petition for review of the BIA's dismissal of her appeal from an immigration judge's denial of asylum and withholding of removal. Because the dispositive question was nexus, the court bypassed her timeliness argument and held under the substantial evidence standard that neither the gang robberies she suffered in El Salvador nor the threats from her niece's father were on account of a protected ground: the robberies were motivated by financial gain, and the threats by revenge after she urged her sister to report the perpetrator to the police. Her withholding-of-removal and humanitarian asylum claims failed for the same reason, and the court deemed her CAT argument undeveloped and her due process claim a repackaging of earlier arguments.