Garcia Samayoa v. Bondi

CourtCourt of Appeals for the Ninth Circuit
DecidedMarch 18, 2025
Docket23-3360
StatusUnpublished

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

Bluebook
Garcia Samayoa v. Bondi, (9th Cir. 2025).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 18 2025 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

LESLIE MERARY GARCIA No. 23-3360 SAMAYOA; SHEILY MIRELLA Agency Nos. LINARES GARCIA, A220-466-196 A220-466-197 Petitioners, MEMORANDUM* v.

PAMELA BONDI, Attorney General,

Respondent.

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

Submitted February 7, 2025** Pasadena, California

Before: WARDLAW, CALLAHAN, and HURWITZ, Circuit Judges.

Leslie Merary Garcia Samayoa (“Garcia”) and Sheily Mirella Linares Garcia

(“Linares”) (together “Petitioners”), natives and citizens of Guatemala, petition for

review of a Board of Immigration Appeals (“BIA”) decision dismissing their

* 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). appeal from an order of an Immigration Judge (“IJ”) denying their petitions for

asylum, withholding of removal, and protection under the Convention Against

Torture (“CAT”). Petitioners also seek review of the BIA’s denial of their

ineffective assistance of counsel claim.

We have jurisdiction under 8 U.S.C. § 1252(a). “Where the BIA adopts and

affirms the IJ’s decision by citing Matter of Burbano, 20 I. & N. Dec. 872 (B.I.A.

1994), it is adopting the IJ’s decision in its entirety.” Lezama-Garcia v. Holder,

666 F.3d 518, 524 (9th Cir. 2011). Where the BIA cites Burbano and also

provides its own review of the evidence and the law, we review both the IJ’s and

the BIA’s decisions. Ruiz-Colmenares v. Garland, 25 F.4th 742, 748 (9th Cir.

2022). We review legal conclusions de novo and factual findings for substantial

evidence. J.R. v. Barr, 975 F.3d 778, 781 (9th Cir. 2020).1 We deny the petition

for review.

1. This case presents threshold questions as to whether Petitioners forfeited

or abandoned their arguments on appeal as to (1) ineffective assistance of counsel

and (2) the denial of asylum, withholding of removal, and protection under the

1 There is disagreement within the Ninth Circuit over the standard of review for determining whether a “particular set of facts does or does not rise to the level of persecution.” Fon v. Garland, 34 F.4th 810, 816 (9th Cir. 2022) (Graber, J., concurring); id. at 820 (Collins, J., concurring); compare Kaur v. Wilkinson, 986 F.3d 1216, 1221 (9th Cir. 2021) (de novo), with Villegas Sanchez v. Garland, 990 F.3d 1173, 1179 (9th Cir. 2021) (substantial evidence). We need not resolve this issue, however, because no matter the standard of review, Petitioners’ claims fail.

2 23-3360 CAT. Federal Rule of Appellate Procedure 28(a)(8) requires an opening brief to

provide argument containing, among other things, “appellant’s contentions and the

reasons for them, with citations to the authorities and parts of the record on which

the appellant relies.” Fed. R. App. P. 28(a)(8)(A). We have made clear that issues

not “specifically and distinctly” argued in the opening brief may be deemed

forfeited, Hernandez v. Garland, 47 F.4th 908, 916 (9th Cir. 2022) (as amended)

(citation omitted), and “[i]ssues raised in a brief that are not supported by argument

are deemed abandoned,” Martinez-Serrano v. INS, 94 F.3d 1256, 1259 (9th Cir.

1996).

The government argues that Petitioners abandoned their argument as to

ineffective assistance of counsel. We disagree. Petitioners’ opening brief

presented at least one argument related to prior counsel’s withdrawal of material

evidence, which they claim prejudiced them in their immigration proceedings.

Accordingly, Petitioners sufficiently raised this issue in their opening brief. See

Martinez-Serrano, 94 F.3d at 1259–60.

The government similarly argues “Petitioners’ opening brief does not

meaningfully challenge dispositive bases for the agency’s denial of their

applications for asylum and related relief[,]” including “the agency’s denial of their

CAT protection claim.” We again disagree. The opening brief argues the BIA

erred in finding (1) the harm Petitioners claimed did not rise to the level of

3 23-3360 persecution, (2) the proposed particular social group was not cognizable, (3) there

was no nexus, and (4) that Petitioners failed to establish a clear probability of

torture by or with the acquiescence of a government official. These arguments are

sufficiently specific and distinct to fairly present them to this court. See

Hernandez, 47 F.4th at 916.

2. We turn to the merits. The right to effective assistance of counsel in

immigration proceedings stems from the Fifth Amendment’s guarantee of due

process. See Mohammed v. Gonzales, 400 F.3d 785, 793 (9th Cir. 2005). To

assert ineffective assistance of counsel, a noncitizen must generally comply with

the requirements set forth in Matter of Lozada, 19 I. & N. Dec. 637 (B.I.A. 1988).

See Melkonian v. Ashcroft, 320 F.3d 1061, 1071–72 (9th Cir. 2003). Under

Lozada, the noncitizen must “(1) provide an affidavit describing in detail the

agreement with counsel; (2) inform counsel of the allegations and afford counsel

an opportunity to respond; and (3) report whether a complaint of ethical or legal

violations has been filed, and if not, why.” Id. at 1072 (citing Lozada, 19 I. & N.

Dec. at 639). However, “[t]he Lozada factors are not rigidly applied, especially

where their purpose is fully served by other means.” Morales Apolinar v.

Mukasey, 514 F.3d 893, 896 (9th Cir. 2008).

It is undisputed that Petitioners did not comply with the requirements

outlined in Lozada. The question then, is whether the alleged ineffectiveness is so

4 23-3360 plain on its face that Petitioners’ noncompliance can be excused. See Guan v.

Barr, 925 F.3d 1022, 1033 (9th Cir. 2019). Here, the alleged ineffectiveness

relates to Petitioners’ prior counsel withdrawing screenshots of threatening

Facebook messages. Petitioners, however, cite no authority finding that such

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Related

Lezama-Garcia v. Holder
666 F.3d 518 (Ninth Circuit, 2011)
Arout Melkonian v. John Ashcroft, Attorney General
320 F.3d 1061 (Ninth Circuit, 2003)
Morales Apolinar v. Mukasey
514 F.3d 893 (Ninth Circuit, 2008)
Hayk Khudaverdyan v. Eric Holder, Jr.
778 F.3d 1101 (Ninth Circuit, 2015)
Jiang Guan v. William Barr
925 F.3d 1022 (Ninth Circuit, 2019)
Carlos Conde Quevedo v. William Barr
947 F.3d 1238 (Ninth Circuit, 2020)
J.R. v. William Barr
975 F.3d 778 (Ninth Circuit, 2020)
Chanpreet Kaur v. Robert Wilkinson
986 F.3d 1216 (Ninth Circuit, 2021)
Alicia Naranjo Garcia v. Robert Wilkinson
988 F.3d 1136 (Ninth Circuit, 2021)
Francisca Villegas Sanchez v. Merrick Garland
990 F.3d 1173 (Ninth Circuit, 2021)
Zhirayr Lalayan v. Merrick Garland
4 F.4th 822 (Ninth Circuit, 2021)
M-E-V-G
26 I. & N. Dec. 227 (Board of Immigration Appeals, 2014)
BURBANO
20 I. & N. Dec. 872 (Board of Immigration Appeals, 1994)
LOZADA
19 I. & N. Dec. 637 (Board of Immigration Appeals, 1988)
Juan Ruiz-Colmenares v. Merrick Garland
25 F.4th 742 (Ninth Circuit, 2022)
Stephen Fon v. Merrick Garland
34 F.4th 810 (Ninth Circuit, 2022)
Jose Hernandez v. Merrick Garland
47 F.4th 908 (Ninth Circuit, 2022)

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