Andrade v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 16, 2026
Docket24-2806
StatusUnpublished

This text of Andrade v. Bondi (Andrade v. Bondi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrade v. Bondi, (2d Cir. 2026).

Opinion

24-2806 Andrade v. Bondi BIA Schultz, IJ A094 476 777

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 16th day of January, two thousand twenty-six.

PRESENT: JON O. NEWMAN, GERARD E. LYNCH, SARAH A. L. MERRIAM, Circuit Judges. _____________________________________ JORGE ALBERTO ANDRADE, Petitioner,

v. 24-2806 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Aaron J. Aisen, Michaela Andriatch, Erie County Bar Association Volunteer Lawyers Project, Batavia, NY. FOR RESPONDENT: Brett A. Schumate, Assistant Attorney General; Margot P. Kniffin, Rebecca Hoffberg Phillips, Senior Litigation Counsel, Office of Immigration Litigation, United States Department of Justice, Washington, DC.

UPON DUE CONSIDERATION of this petition for review of a Board of

Immigration Appeals (“BIA”) decision, it is hereby ORDERED, ADJUDGED, AND

DECREED that the petition for review is GRANTED, the removal order is

VACATED, and the case is remanded for further consideration consistent with this

order.

Petitioner Jorge Alberto Andrade, a native and citizen of El Salvador, seeks

review of an October 23, 2024, decision of the BIA affirming a May 6, 2024, decision

of an Immigration Judge (“IJ”) denying Andrade’s application for protection

under the Convention Against Torture (“CAT”). In re Andrade, No. A 094 476 777

(B.I.A. Oct. 23, 2024), aff’g No. A 094 476 777 (Immig. Ct. Batavia May 6, 2024). We

assume the parties’ familiarity with the underlying facts and procedural history.

We review the IJ’s decision as supplemented by the BIA. See Yan Chen v.

Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). We review findings of fact for

substantial evidence and questions of law and application of law to fact de novo.

See Quintanilla-Mejia v. Garland, 3 F.4th 569, 583 (2d Cir. 2021). “[T]he

2 administrative findings of fact are conclusive unless any reasonable adjudicator

would be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B).

“[W]e presume that [the agency] has taken into account all of the evidence before

[it], unless the record compellingly suggests otherwise.” Xiao Ji Chen v. U.S. Dep’t

of Just., 471 F.3d 315, 336 n.17 (2d Cir. 2006). However, remand is warranted if the

agency “overlook[s] key evidence and mischaracterize[s] the record,” Doe v.

Sessions, 886 F.3d 203, 211 (2d Cir. 2018), or where there is insufficient reasoning

for judicial review, see Poradisova v. Gonzales, 420 F.3d 70, 77 (2d Cir. 2005).

A CAT applicant must show he will “more likely than not” be tortured “if

removed to the proposed country of removal.” 8 C.F.R. § 1208.16(c)(2). “Torture

is . . . any act by which severe pain or suffering, whether physical or mental, is

intentionally inflicted . . . by, or at the instigation of, or with the consent or

acquiescence of, a public official acting in an official capacity or other person acting

in an official capacity.” Id. § 1208.18(a)(1). The more likely than not standard

“requires the applicant to establish that there is greater than a fifty percent

chance . . . that he will be tortured.” Chun Gao v. Gonzales, 424 F.3d 122, 128–29

(2d Cir. 2005) (quotation marks omitted). Whether an applicant meets this

threshold “must be considered in terms of the aggregate risk of torture from all

3 sources, and not as separate, divisible . . . claims.” Matter of J-R-G-P-, 27 I. & N.

Dec. 482, 484 (B.I.A. 2018) (quotation marks omitted).

The agency found that, while Andrade would likely be detained under the

state of exception, 1 he had not established likely torture by Salvadoran officials

because (1) the risk of intentional torture by prison guards, police, or other officials

was speculative as there were only anecdotal reports of torture, (2) there was

insufficient evidence that pain and suffering caused by prison conditions would

be intentionally inflicted, and (3) the record did not demonstrate that officials

would acquiesce to Andrade’s torture by other incarcerated gang members. As

discussed below, we remand because the agency did not address all evidence

relevant to the risk of torture by prison officials or to the intentional imposition of

harsh prison conditions. We find no error in the agency’s determination that

Andrade did not demonstrate that he would more likely than not be tortured by

rival gang members with the acquiescence of public officials.

I. Torture by Salvadoran Prison Officials

Andrade’s expert witness, Dr. Robert Kirkland, stated:

1 The “régimen de excepción” or state of exception, enacted in March 2022, is a national law of El Salvador under which known or suspected gang members may be arrested and imprisoned with little process. See Certified Administrative Record (“CAR”) at 310 (2022 State Dep’t Rep.)

4 The extreme violence in Salvadoran prisons is a matter of state- sanctioned policy and practice. Guards and police beat detainees to try to force them to “confess” to gang membership, in addition to beating and punishing detainees simply to inflict pain and suffering. Many prisoners have died while in state custody under circumstances that suggest torture and abuse as the cause of death, such as death certificates that list “mechanical asphyxia,” “multiple unidentified traumas,” or “badly beaten” as the principal cause of death . . . [and] Amnesty International and others have suggested that the prison conditions in El Salvador amount to “a policy of systematically torturing everyone who is detained under the state of emergency because they are suspected of being gang members.”

CAR at 294 (Kirkland Aff.); see also id. at 316 (2022 State Dep’t Rep.) (reporting 35

detainee deaths from “causes such as strangulation, blunt force trauma, or other

causes that could indicate torture or mistreatment”), 367 (2023 Amnesty Int’l Art.)

(reporting “deaths of 190 individuals while in state custody—some as a result of

torture or other ill-treatment”), 389 (2022 Intercept Art.) (“[T]he few people

released from prisons—mostly minors—have shown signs of being beaten,

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Related

Jian Hui Shao v. Mukasey
546 F.3d 138 (Second Circuit, 2008)
Pierre v. Gonzales
502 F.3d 109 (Second Circuit, 2007)
Yan Chen v. Alberto Gonzales, Attorney General, 1
417 F.3d 268 (Second Circuit, 2005)
Chun Gao v. Alberto R. Gonzales, Attorney General
424 F.3d 122 (Second Circuit, 2005)
Gallina v. Wilkinson
988 F.3d 137 (Second Circuit, 2021)
Quintanilla v. Garland
3 F.4th 569 (Second Circuit, 2021)
J-R-G-P
27 I. & N. Dec. 482 (Board of Immigration Appeals, 2018)
Doe v. Sessions
886 F.3d 203 (Second Circuit, 2018)

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Andrade v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/andrade-v-bondi-ca2-2026.