Umana-Ramos v. Holder, No. 12-4274 (6th Cir. 2013)
Annotate this CaseRamos, a citizen of El Salvador, entered the U.S. without inspection or authorization in 2009, at the age of 14. In removal proceedings, he sought asylum and withholding of removal, claiming that, in El Salvador, members of a gang had begun attempting to recruit him when he was 11 years old and had threatened to beat him if he refused to join. Neither Ramos nor acquaintances, having refused to join, were physically harmed by gang members. A member of the gang was arrested for the murder of a neighbor child who had stolen gang property. An Immigration Judge and the Board of Immigration Appeals found that Ramos had not established membership in a particular social group protected under the Immigration and Nationality Act. The Sixth Circuit denied review, noting that the social visibility of a particular social group refers to whether those with the relevant shared characteristic are perceived as a group by society, rather than whether the group’s individual members are visually recognizable “on-sight.”
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