Diaz Pulig v. Blanche

CourtCourt of Appeals for the Second Circuit
DecidedApril 10, 2026
Docket24-2359
StatusUnpublished

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

Opinion

24-2359 Diaz Pulig v. Blanche BIA Chung, IJ A246 265 111/112/113

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.

1 At a stated term of the United States Court of Appeals for the Second 2 Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley 3 Square, in the City of New York, on the 10th day of April, two thousand 4 twenty-six. 5 6 PRESENT: 7 REENA RAGGI, 8 JOSEPH F. BIANCO, 9 MARIA ARAÚJO KAHN, 10 Circuit Judges. 11 _____________________________________ 12 13 JOSSELYN DANIELA DIAZ PULIG, 14 N.J.A.D., D.J.A.D., 15 Petitioners, 16 17 v. 24-2359 18 NAC 19 TODD BLANCHE, ACTING UNITED 20 STATES ATTORNEY GENERAL, 21 Respondent.* 22 _____________________________________

* The Clerk of Court is respectfully directed to amend the caption as set forth above. 1 FOR PETITIONERS: Reuben S. Kerben, Esq., Kerben Law Firm, 2 P.C., Kew Gardens, NY. 3 4 FOR RESPONDENT: Yaakov M. Roth, Acting Assistant Attorney 5 General; Robert D. Tennyson, Senior 6 Litigation Counsel; Remi Da Rocha-Afodu, 7 Trial Attorney, Office of Immigration 8 Litigation, United States Department of 9 Justice, Washington, DC.

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

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

12 DECREED that the petition for review is DENIED.

13 Petitioners Josselyn Daniela Diaz Pulig and her two minor children, natives

14 and citizens of Ecuador, seek review of an August 23, 2024, decision of the BIA

15 affirming an April 11, 2024, decision of an Immigration Judge (“IJ”) denying Diaz

16 Pulig’s application for asylum, withholding of removal, and relief under the

17 Convention Against Torture (“CAT”). 1 In re Diaz Pulig, et al., Nos. A246-265-

1 We principally refer to Diaz Pulig because her children are derivative asylum beneficiaries and did not file independent applications. We do not address the merits of Diaz Pulig’s CAT claim because it is both abandoned and unexhausted, as she does not challenge either the BIA’s determination that she waived that claim by failing to address it on appeal or the IJ’s finding that she failed to meet her burden of proof. See Vera Punin v. Garland, 108 F.4th 114, 124 (2d Cir. 2024) (“[W]hen an argument made to this Court cannot be closely matched up with a specific argument made to the BIA, it has not been properly exhausted and we cannot hear it.”); Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (considering 2 1 111/112/113 (B.I.A. Aug. 23, 2024), aff’g Nos. A246-265-111/112/113 (Immig. Ct.

2 N.Y.C. Apr. 11, 2024). We assume the parties’ familiarity with the underlying

3 facts and procedural history.

4 We review the IJ’s decision as modified and supplemented by the BIA. See

5 Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005); Yan Chen v.

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

7 substantial evidence and questions of law de novo. See Hongsheng Leng v.

8 Mukasey, 528 F.3d 135, 141 (2d Cir. 2008). “[T]he administrative findings of fact

9 are conclusive unless any reasonable adjudicator would be compelled to conclude

10 to the contrary.” 8 U.S.C. § 1252(b)(4)(B).

11 To establish eligibility for asylum or withholding of removal, Diaz Pulig had

12 to show that she suffered past persecution or has a well-founded fear of future

13 persecution and that “race, religion, nationality, membership in a particular social

14 group, or political opinion was or will be at least one central reason for” the

15 persecution. 8 U.S.C. § 1158(b)(1)(B)(i); id. § 1231(b)(3)(A); 8 C.F.R. §§ 1208.13(b),

“abandoned any claims not adequately presented in an appellant’s brief” (quotation marks omitted)); Prabhudial v. Holder, 780 F.3d 553, 555–56 (2d Cir. 2015) (when the BIA deems an issue waived, our review “is limited to whether the BIA erred in deeming the argument waived”). 3 1 1208.16(b); see Quituizaca v. Garland, 52 F.4th 103, 109–14 (2d Cir. 2022); Chavez-

2 Suntaxi v. Bondi, No. 23-7216, 2025 WL 2155150, at *1 (2d Cir. July 30, 2025)

3 (summary order) (“[T]he ‘one central reason’ standard applies to both asylum and

4 withholding of removal.”). To prevail on a particular social group claim, she also

5 had to establish that her proposed groups were cognizable, which requires a

6 showing that members of the group share “a common immutable characteristic,”

7 that the group is “defined with particularity,” and that it is “socially distinct within

8 the society in question.” Paloka v. Holder, 762 F.3d 191, 196 (2d Cir. 2014) (quoting

9 Matter of M–E–V–G–, 26 I. & N. Dec. 227, 237 (B.I.A. 2014)). Particularity requires

10 that the group be “defined by characteristics that provide a clear benchmark for

11 determining who falls within the group” and that membership not be

12 “amorphous, overbroad, diffuse, or subjective.” Id. Social distinction requires

13 that “society as a whole views a group as socially distinct.” Id.

14 The agency did not err in concluding that Diaz Pulig failed to make the

15 required showing of nexus to a cognizable particular social group. See id. at 195

16 (cognizability of a particular social group is a legal determination reviewed de

17 novo); Edimo-Doualla v. Gonzales, 464 F.3d 276, 282–83 (2d Cir. 2006) (reviewing

18 nexus determination for substantial evidence). Diaz Pulig alleged past and

4 1 feared persecution on account of membership in two particular social groups:

2 “vulnerable Ecuadorian women” and “crime victims and witnesses who report to

3 law enforcement.”

4 As to the first group, the agency found that it was not defined with

5 particularity or socially distinct. Diaz Pulig misreads the IJ’s decision as having

6 assumed that the group is socially distinct, and fails to challenge that aspect of the

7 IJ’s decision—thereby abandoning an issue that is dispositive of cognizability.

8 See Debique, 58 F.4th at 684; Paloka, 726 F.3d at 196. Instead, she advances a

9 conclusory argument that this group satisfies the particularity requirement

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Related

Yan Chen v. Alberto Gonzales, Attorney General, 1
417 F.3d 268 (Second Circuit, 2005)
Hong Ying Gao v. Alberto Gonzales, 1
440 F.3d 62 (Second Circuit, 2006)
Yves Gautier Edimo-Doualla v. Alberto R. Gonzales, 1
464 F.3d 276 (Second Circuit, 2006)
Ucelo-Gomez v. Mukasey
509 F.3d 70 (Second Circuit, 2007)
Hongsheng Leng v. Mukasey
528 F.3d 135 (Second Circuit, 2008)
Silvana Paloka v. Eric H. Holder, Jr.
762 F.3d 191 (Second Circuit, 2014)
W-Y-C-& H-O-B
27 I. & N. Dec. 189 (Board of Immigration Appeals, 2018)
M-E-V-G
26 I. & N. Dec. 227 (Board of Immigration Appeals, 2014)
ACOSTA
19 I. & N. Dec. 211 (Board of Immigration Appeals, 1985)
Quituizaca v. Garland
52 F.4th 103 (Second Circuit, 2022)
Prabhudial v. Holder
780 F.3d 553 (Second Circuit, 2015)
Garcia-Aranda v. Garland
53 F.4th 752 (Second Circuit, 2022)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Vera Punin v. Garland
108 F.4th 114 (Second Circuit, 2024)

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