Barrera v. Blanche

CourtCourt of Appeals for the Second Circuit
DecidedJuly 9, 2026
Docket24-2266
StatusUnpublished

This text of Barrera v. Blanche (Barrera v. Blanche) 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
Barrera v. Blanche, (2d Cir. 2026).

Opinion

24-2266 Cuadrado-Barrera v. Blanche BIA Reid, IJ A246 563 788/789

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 9th day of July, two thousand twenty- six.

PRESENT: JON O. NEWMAN, MICHAEL H. PARK, WILLIAM J. NARDINI, Circuit Judges. _____________________________________ LIZBETH CAROLINA CUADRADO- BARRERA, S.N. S.-C., Petitioners,

v. 24-2266 NAC TODD BLANCHE, ACTING UNITED STATES ATTORNEY GENERAL, Respondent. *

*We use only initials to refer to the minor petitioner in this publicly accessible order, consistent with Fed. R. Civ. P. 5.2(a)(3) and Fed. R. App. P. 25(a)(5). The Clerk of Court is respectfully directed to amend the caption as set forth above. _____________________________________

FOR PETITIONERS: Michael Borja, Borja Law Firm, P.C., Jackson Heights, NY.

FOR RESPONDENT: Yaakov Roth, Acting Assistant Attorney General; Anthony P. Nicastro, Assistant Director, Office of Immigration Litigation; Peter Gannon, Trial Attorney, Office of Immigration Litigation; Civil Division, 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 DENIED.

Petitioners Lizbeth Carolina Cuadrado-Barrera and her minor child, natives

and citizens of Ecuador, seek review of a July 31, 2024, decision of the BIA

affirming a March 19, 2024, decision of an Immigration Judge (“IJ”) denying

asylum, withholding of removal, and relief under the Convention Against Torture

(“CAT”). In re Lizbeth Carolina Cuadrado-Barrera, et al., Nos. A246 563 788/789

(B.I.A. July 31, 2024), aff’g Nos. A246 563 788/789 (Immig. Ct. N.Y. City Mar. 19,

2024). We assume the parties’ familiarity with the underlying facts and procedural

history.

We have reviewed the IJ’s decision as modified and supplemented by the

BIA. See Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005); Yan 2 Chen v. Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). We review the agency’s factual

findings, including a nexus determination, for substantial evidence. See Hong Fei

Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018); Edimo-Doualla v. Gonzales, 464 F.3d

276, 282 (2d Cir. 2006). “[T]he 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).

The agency determined that Cuadrado-Barrera did not demonstrate that the

abuse she suffered from her former partner had a nexus to a protected ground or

that she would likely be tortured if she returned to Ecuador. An applicant for

asylum and withholding of removal must establish either past persecution or a

fear of future persecution and “that race, religion, nationality, membership in a

particular social group, or political opinion was or will be at least one central

reason for persecuting the applicant.” 8 U.S.C. § 1158(b)(1)(B)(i) (asylum); see also

id. § 1231(b)(3)(A), (C) (withholding); 8 C.F.R. §§ 1208.13(b), 1208.16(b). Contrary

to Cuadrado-Barrera’s assertions otherwise, the “one central reason” standard

applies to both asylum and withholding of removal. See Quituizaca v. Garland, 52

F.4th 103, 105–06 (2d Cir. 2022). The protected ground “cannot be a minor,

incidental, or tangential reason for the harm.” Garcia-Aranda v. Garland, 53 F.4th

752, 757 (2d Cir. 2022). 3 Cuadrado-Barrera does not meaningfully challenge the agency’s dispositive

nexus finding. She states that “[t]here is no challenge to the Immigration Court in

the factual record,” Petitioners’ Br. at 5, and argues only that the BIA failed to cite

precedent relevant to analyzing a claim based on domestic abuse. She states that

she “clearly suffered persecution as a member of the class of Ecuadorian women

unable to leave their relationships,” id. at 9 (cleaned up), but she does not elaborate

or cite facts to support her claim. Accordingly, Cuadrado-Barrera has abandoned

review of the basis for the denial of asylum and withholding of removal by not

presenting a sufficient argument. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir.

2023) (“We consider abandoned any claims not adequately presented in an

appellant’s brief, and an appellant’s failure to make legal or factual arguments

constitutes abandonment.” (quotation marks omitted)); Yueqing Zhang v. Gonzales,

426 F.3d 540, 545 n.7 (2d Cir. 2005) (deeming a claim abandoned where petitioner

“devote[d] only a single conclusory sentence to the argument”).

Like her asylum and withholding claims, Cuadrado-Barrera does not

meaningfully address CAT relief and has therefore also abandoned review of that

claim. See Debique, 58 F.4th at 684. Analysis of a CAT claim is a “two-step inquiry”

that requires an applicant to establish that torture is “more likely than not” and

that “sufficient state action . . . would be involved in [the applicant’s] likely future 4 harm.” Garcia-Aranda, 53 F.4th at 758–59. Cuadrado-Barrera cites one fact in

support of her CAT claim—her testimony that her former partner was a “very,

very aggressive person.” Certified Administrative Record at 138. She also states

that the agency erred in requiring her to show acquiescence to torture to state a

CAT claim.

The fact that her partner was aggressive is insufficient to challenge the

denial of CAT relief because a CAT applicant has the burden to show that future

torture is “more likely than not.” 8 C.F.R. § 1208.16(c)(2); see Garcia-Aranda, 53

F.4th at 758–59. And her challenge to the acquiescence requirement is

unsupported and contrary to the regulations, which require either state action or

torture “with the consent or acquiescence of[] a public official.” 8 C.F.R.

§ 1208.18(a)(1). She argues that “the Ecuadorian government does not have to

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Scarlett v. Barr
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Quintanilla v. Garland
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Quituizaca v. Garland
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Gao v. Sessions
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Garcia-Aranda v. Garland
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Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
M-S-I
29 I. & N. Dec. 61 (Board of Immigration Appeals, 2025)

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