Enedina Liset Ramirez-Lopez v. U.S. Attorney General

Court of Appeals for the Eleventh Circuit·Decided March 6, 2025·No. 24-11249·Unpublished

Opinion

[DO NOT PUBLISH]

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-11249

Non-Argument Calendar

ENEDINA LISET RAMIREZ-LOPEZ, KIMBERLY MAYDALY CHAVEZ-RAMIREZ, Petitioners,

versus U.S. ATTORNEY GENERAL,

Respondent.

Petition for Review of a Decision of the Board of Immigration Appeals Agency No. A220-306-839

2 Opinion of the Court 24-11249

Before JORDAN, LUCK, and KIDD, Circuit Judges. PER CURIAM:

Enedina Ramirez-Lopez, proceeding as the lead petitioner on behalf of herself and her minor child, petitions for review of the Board of Immigration Appeals’s (“BIA”) order affirming the denial of her application for asylum and withholding of removal. She argues that the BIA ignored binding precedent and erred in finding that there was no nexus between the harm she suffered and her membership in a particular social group. After careful review, we deny the petition.

I. BACKGROUND

Ramirez-Lopez is a native and citizen of Guatemala who entered the United States in June 2021 with her daughter, Kimberly Chavez-Ramirez (“Kimberly”). The Department of Homeland Security issued notices to appear, charging both Ramirez-Lopez and Kimberly with being removable as aliens present in the United States without being admitted or paroled, pursuant to the Immigration and Nationality Act (“INA”), 8 U.S.C. § 1182(a)(6)(A)(i). Through counsel, they both conceded removability.

Ramirez-Lopez then applied for asylum, withholding of removal , and relief under the United Nations Convention Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment (“CAT”), designating Kimberly as a derivative beneficiary of the requested relief. Ramirez-Lopez alleged that, after the

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death of Arturo Rocael Chavez Funes (“Rocael”), her partner and Kimberly’s father, his family used fraudulent and violent tactics to evict them from their home, and because she and Kimberly threatened Rocael’s family’s current ownership of the property, she and Kimberly would be in danger if they returned to Guatemala.

Ramirez-Lopez offered several documents in support of her application, including a written statement in which she elaborated on her experiences in Guatemala. Ramirez-Lopez explained that she, Rocael, and Kimberly were living together in Rocael’s home when Rocael died in 2017. After Rocael’s passing, Kimberly inherited the property, so they continued living there. Although there was documentation of Kimberly’s inheritance of the home, Rocael’s family fraudulently changed the deed to reflect that Rocael’s mother, Catalina Funes (“Catalina”), owned the property. Catalina then instituted eviction proceedings, and Rocael’s family used threats and violence to intimidate Ramirez-Lopez. Although Ramirez-Lopez reported their actions to the police and hired an attorney to fight for ownership of the property, she and Kimberly were eventually evicted, and the family faced no criminal consequences . When threats from Rocael’s family continued following the eviction, Ramirez-Lopez and Kimberly came to the United States.

At a removal hearing before an immigration judge, Ramirez-Lopez’s counsel clarified that she sought asylum and withholding of removal based on the following particular social groups: (1) family of Kimberly, (2) Guatemalan women, (3) women

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who inherit property, (4) women lacking male protection, and (5) unmarried Guatemalan women. Ramirez-Lopez was questioned by her counsel, the government, and the immigration judge, and she elaborated upon the allegations made in her application and written statement.

During her testimony, Ramirez Lopez explained that, while she had no proof of Rocael’s ownership of the property and he did not leave a will, Rocael orally stated before his death that the house belonged to his daughter. Ramirez-Lopez believed that Catalina, who was cordial with Kimberly prior to Rocael’s death, was motivated to obtain the property for her family and objected to the arrangement Rocael desired because Kimberly was a girl and Ramirez-Lopez and Rocael never married. Soon after Rocael’s death, his uncle came to the house and stole the documents that evidenced Kimberly’s ownership of the property. During this incident , he assaulted Ramirez-Lopez, stole money, stated that the property belonged to his family, and warned Ramirez-Lopez that if she tried to interfere, the family would hurt her and Kimberly.

Once the ownership documents were altered, Catalina initiated eviction proceedings, alleging that Ramirez-Lopez should vacate the home and that Kimberly, as a girl, had no inheritance rights to the property. While these eviction proceedings were ongoing, issues continued between Rocael’s family and Ramirez-Lopez. She recalled that, on one occasion, Rocael’s aunt came to the property with a knife, chain, and lock, and called Kimberly a “problem” that she would “eliminate.” Other members of Rocael’s family soon

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arrived at the property and called for Kimberly and Ramirez-Lopez to be burned inside the locked house. Although police rescued Ramirez-Lopez and Kimberly, Rocael’s family did not face any criminal consequences and proceeded with their efforts to verbally threaten, attack, mock, and intimidate Ramirez-Lopez.

Ramirez-Lopez further testified that, after approximately three years of legal proceedings, a court granted Catalina ownership of the house, and she moved onto the property, telling everyone that it belonged to one of her surviving sons. Ramirez-Lopez began doing housework for friends and neighbors in exchange for alternative places to stay, but Rocael’s family continued to harass her and threaten that Kimberly would “sooner or later . . . be eliminated ” and never regain possession of the house. Because members of Rocael’s family belonged to gangs, and the Guatemalan authorities were unable to provide protection, Ramirez-Lopez also believed she and Kimberly would be in danger if they returned to Guatemala.

Following the hearing, the immigration judge issued an oral decision denying relief. The immigration judge found that Ramirez-Lopez testified credibly but failed to show a nexus between the harm she suffered and an enumerated ground for relief under the INA. The immigration judge explained that, although he was sympathetic to Ramirez-Lopez’s situation, her testimony revealed an inter-family dispute, and the family’s reason for causing harm was about financial gain and property ownership rather than Ramirez-Lopez’s membership in any particular social group. The

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immigration judge therefore concluded that, because no nexus existed between the experienced harm and membership in a particular social group, Ramirez-Lopez failed to show past persecution. The immigration judge also found that Ramirez-Lopez had not demonstrated a well-founded fear of future persecution, since the property at issue was no longer hers, and no evidence indicated she would face any problems if she returned to Guatemala. As such, the immigration judge determined that Ramirez-Lopez failed to meet her burden of proving eligibility for asylum or withholding of removal. The immigration judge likewise concluded that Ramirez-Lopez presented insufficient evidence to demonstrate eligibility for CAT relief.

Ramirez-Lopez appealed the immigration judge’s decision to the BIA and argued that she provided sufficient credible evidence to show she suffered past persecution because of her membership in the five particular social groups she proposed before the immigration judge. She also argued that the immigration judge overlooked Circuit precedent when rendering his decision, and she referenced Perez-Sanchez v. United States Attorney General, 935 F.3d 1148 (11th Cir. 2019) and Sanchez-Castro v. United States Attorney General, 998 F.3d 1281 (11th Cir. 2021).

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