Garcia-Manzanares v. Bondi

CourtCourt of Appeals for the Fifth Circuit
DecidedJanuary 2, 2026
Docket25-60284
StatusUnpublished

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

Bluebook
Garcia-Manzanares v. Bondi, (5th Cir. 2026).

Opinion

Case: 25-60284 Document: 46-1 Page: 1 Date Filed: 01/02/2026

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit No. 25-60284 Summary Calendar FILED ____________ January 2, 2026 Lyle W. Cayce Luz Ilvea Garcia-Manzanares, Clerk

Petitioner,

versus

Pamela Bondi, U.S. Attorney General,

Respondent. ______________________________

Petition for Review of an Order of the Board of Immigration Appeals Agency No. A208 140 808 ______________________________

Before Higginbotham, Engelhardt, and Ramirez, Circuit Judges. Per Curiam: * Luz Ilvea Garcia-Manzanares, a native and citizen of El Salvador, petitions for review of an order of the Board of Immigration Appeals (BIA) dismissing her appeal of an Immigration Judge’s order that she be removed and denying her application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). We review the _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 25-60284 Document: 46-1 Page: 2 Date Filed: 01/02/2026

No. 25-60284

denial of asylum and withholding claims for substantial evidence. Zhang v. Gonzales, 432 F.3d 339, 344 (5th Cir. 2005). Under the substantial evidence standard, this court may not disturb the BIA’s decision unless the evidence “compels” a contrary conclusion. Id. (internal quotation marks and citation omitted). Garcia-Manzanares has not made this showing. The BIA’s conclusion that her proposed particular social group (PSG) of Salvadoran women unable to leave their domestic relationships was not cognizable comports with our jurisprudence. See Lopez-Perez v. Garland, 35 F.4th 953, 958 (5th Cir. 2022); Gonzales-Veliz v. Barr, 938 F.3d 219, 232 (5th Cir. 2019). Her argument that these cases should not be followed under Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), fails. Loper Bright explained that, while it was overruling Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), it was “not call[ing] into question prior cases that relied on the Chevron framework,” 603 U.S. at 412. Her argument grounded in Loper Bright is thus unavailing. See id. Because she shows no error in connection with the BIA’s rejection of her proposed PSG, which is an essential element of asylum and withholding claims, these claims fail, and there is no need to consider her remaining arguments concerning them. See Munoz-De Zelaya v. Garland, 80 F.4th 689, 693-94 (5th Cir. 2023); Jaco, 24 F.4th at 401. In her opening brief, Garcia-Manzanares does not fully address the CAT issue, does not provide accurate record cites to the facts underlying it, and presents only a conclusory two-sentence argument concerning one element of the pertinent test. Accordingly, this issue is forfeited for want of adequate briefing. See United States v. Stalnaker, 571 F.3d 428, 439 & n.9 (5th Cir. 2009). The petition for review is DENIED.

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Related

Yi Wu Zhang v. Gonzales
432 F.3d 339 (Fifth Circuit, 2005)
United States v. Stalnaker
571 F.3d 428 (Fifth Circuit, 2009)
Maria Gonzales-Veliz v. William Barr, U. S. Atty G
938 F.3d 219 (Fifth Circuit, 2019)
Lopez-Perez v. Garland
35 F.4th 953 (Fifth Circuit, 2022)
Munoz-De Zalaya v. Garland
80 F.4th 689 (Fifth Circuit, 2023)
Loper Bright Enterprises v. Raimondo
603 U.S. 369 (Supreme Court, 2024)

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Bluebook (online)
Garcia-Manzanares v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-manzanares-v-bondi-ca5-2026.