Blanco De Guevara v. Barr, No. 18-1080 (8th Cir. 2019)
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The Eighth Circuit denied a petition for review of the BIA's decision affirming the IJ's denial of petitioner's application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court agreed with the BIA that the harm petitioner suffered -- being threatened by a phone call and letter from a gang demanding money -- did not constitute past persecution. The court held that substantial evidence supported the BIA's ultimate finding that petitioner failed to prove that she had a well-founded fear of future persecution if removed to El Salvador.
The court also held that the BIA did not err in ruling that petitioner failed to prove past persecution on account of her membership in two particular social groups: Salvadoran female heads of households and vulnerable Salvadoran females. Petitioner's claims for withholding of removal and relief under the CAT likewise failed.
Court Description: Loken, Author, withe Melloy and Erickson, Circuit Judges] Petition for Review - Immigration. The BIA did not err in ruling that petitioner had failed to prove past persecution on account of her membership in two particular social groups - Salvadoran female heads of households and vulnerable Salvadoran females - because the groups are not cognizable social groups in that they lack the necessary social distinction and particularity; denial of asylum claims was supported by substantial evidence on the record as a whole.
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