Ayala v. Blanche

Court of Appeals for the Ninth Circuit·Decided April 16, 2026·No. 25-3878·Unpublished

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 16 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

GERAL AYALA; MARCELA MORALES; No. 25-3878 M. M., Agency Nos. A243-086-919 Petitioners, A243-086-920 A243-086-921 v.

TODD BLANCHE, Acting Attorney MEMORANDUM* General,

Respondent.

On Petition for Review of an Order of the Board of Immigration Appeals

Submitted April 14, 2026** San Francisco, California

Before: RAWLINSON, R. NELSON, and BADE, Circuit Judges.

Geral Ayala, his wife, and his minor daughter (Petitioners), natives and

citizens of Colombia, seek review of a decision of the Board of Immigration

Appeals (BIA) dismissing their appeal from an immigration judge’s (IJ) order

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). denying asylum, withholding of removal, and protection under the Convention

Against Torture (CAT). We have jurisdiction under 8 U.S.C. § 1252, and we deny

the petition.1

1. Substantial evidence supports the agency’s determination that Ayala

and his family did not demonstrate harm rising to the level of persecution. See

Urias-Orellana v. Bondi, 607 U.S. ___, 2026 WL 598435, at *5 (Mar. 4, 2026)

(holding that the substantial evidence standard applies to the agency’s persecution

determination). Contrary to Petitioners’ assertion, the agency considered the

incidents of harm cumulatively. See Sharma v. Garland, 9 F.4th 1052, 1061 (9th

Cir. 2021) (explaining that “all the incidents” of harm should be considered

cumulatively) (citation omitted). Over several years, Ayala experienced

intermittent instances of harm from members of Fortaleza Leoparda Sur, a soccer

fan club of which Ayala was a former member, and others. He was also beaten by

the police as a teenager. None of these incidents involved “significant physical

violence” or serious injuries that required medical treatment. Id. (citation omitted).

Additionally, Ayala’s wife and daughter were never harmed. See id. at 1062

1 As Respondent asserts, Ayala does not challenge the agency’s determination that (1) he failed to demonstrate any past or feared future harm on account of his actual or imputed political opinion, and (2) his wife and daughter failed to establish such harm on account of their membership in the particular social group (PSG) “Immediate family of [Geral Ayala].” Therefore, Petitioners forfeited review of these issues. See Antonio v. Garland, 58 F.4th 1067, 1072 n.7 (9th Cir. 2023).

2 25-3878 (“Another recurring factor that arises in our cases is harms that have befallen a

petitioner’s family members or close friends.”).

Threats, while relevant, do not necessarily compel a finding of past

persecution unless the threats, usually in combination with other mistreatment,

“effect significant actual suffering or harm.” Id. (quoting Hoxha v. Ashcroft, 319

F.3d 1179, 1182 (9th Cir. 2003)). Ayala was threatened with death, but the threats

were unaccompanied by physical violence. He described being assaulted three

times, but he never required medical treatment. Id. at 1061. Thus, the record does

not compel the conclusion that Ayala experienced harm rising to the level of

persecution. See id. at 1063 (discussing non-exhaustive list of relevant factors).

2. The BIA affirmed the IJ’s determination that the proposed PSG

“Colombian witnesses to crimes who are willing to testify against criminals” was

not cognizable because it lacked particularity, and that the proposed PSG “former

members of Fortaleza Leoparda Sur” was not cognizable because it lacked social

distinction.2

Ayala argues that the PSG “former members of Fortaleza Leoparda Sur” is

socially distinct in Colombian society. But his argument relies on conclusory

2 Ayala argues that the BIA erred because both proposed PSGs satisfy the social distinction and the particularity requirements. Our “review is limited to those grounds explicitly relied upon by the [BIA].” Diaz-Reynoso v. Barr, 968 F.3d 1070, 1075 (9th Cir. 2020) (citation omitted). Therefore, we do not consider arguments on issues the BIA did not decide.

3 25-3878 statements based on materials that are not part of the administrative record, and

therefore we cannot rely on them. 8 U.S.C. § 1252(b)(4)(A); see Barrientos v.

Lynch, 829 F.3d 1064, 1067 n.1 (9th Cir. 2016). Ayala has not pointed to any

record evidence compelling a conclusion contrary to the agency’s that this PSG

lacks social distinction.

Ayala argues that the PSG “Colombian witnesses to crime who are willing

to testify” satisfies the particularity requirement. 3 But those who are “willing to

testify” are subject to change and cannot be “easily verified” or “delimited.”

Henriquez-Rivas v. Holder, 707 F.3d 1081, 1091, 1093 (9th Cir. 2013) (concluding

that the PSG “people who testified against gang members” satisfied the

particularity requirement because those who testified could be “easily verified”);

see Santos-Lemus v. Mukasey, 542 F.3d 738, 746 (9th Cir. 2008), abrogated on

other grounds by Henriquez-Rivas, 707 F.3d 1093 (concluding that a PSG based

on general opposition to gang violence is not cognizable).

3. The agency did not err by failing to conduct a nexus analysis between

the harm Ayala alleged and the proposed PSGs. The agency was not required to

3 Ayala also describes this PSG as “[w]itnesses who come to the attention of criminals because they have reported or are willing to testify.” We do not consider this new formulation of the PSG because, as Respondent notes, it was not presented to the agency. See Suate Orellana v. Garland, 101 F.4th 624, 629 (9th Cir. 2024) (holding that even though the administrative exhaustion requirement of 8 U.S.C. § 1252(d)(1) is not jurisdictional, it is a mandatory claim processing rule that a court must enforce if a party raises the issue).

4 25-3878 do so because it found the proposed PSGs not cognizable. See INS v.

Bagamasbad, 429 U.S. 24, 25 (1976) (per curiam) (“As a general rule courts and

agencies are not required to make findings on issues the decision of which is

unnecessary to the results they reach.”). Further, the BIA determined that

Petitioners “did not establish past persecution or a well-founded fear or clear

probability of future persecution on account of a statutorily protected ground.”

4.

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