Guaman-Parades v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedApril 1, 2025
Docket23-7828
StatusUnpublished

This text of Guaman-Parades v. Bondi (Guaman-Parades v. Bondi) 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
Guaman-Parades v. Bondi, (2d Cir. 2025).

Opinion

23-7828 Guaman-Parades v. Bondi BIA Perl, IJ A220 592 351/352/350

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 1st day of April, two thousand twenty- 4 five. 5 6 PRESENT: 7 ROBERT D. SACK, 8 SUSAN L. CARNEY, 9 WILLIAM J. NARDINI, 10 Circuit Judges. 11 _____________________________________ 12 13 VICTOR GUSTAVO GUAMAN- 14 PARADES, JEANPIERRE NICOLAS 15 GUAMAN-ALVARADO, GLORIA 16 SORAYA ALVARADO-MALLA, 17 Petitioners, 18 19 v. 23-7828 20 NAC 21 PAMELA BONDI, UNITED STATES 22 ATTORNEY GENERAL, 23 Respondent. 24 _____________________________________ 1 FOR PETITIONERS: Michael Borja, Esq., Borja Law Firm, P.C., 2 Jackson Heights, NY. 3 4 FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant 5 Attorney General; John S. Hogan, Assistant 6 Director; Lindsay Corliss, Trial Attorney, 7 Office of Immigration Litigation, United 8 States Department of Justice, Washington, 9 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 Victor Gustavo Guaman-Parades, Gloria Soraya Alvarado-

14 Malla, and their minor son Jeanpierre Nicolas Guaman-Alvarado, natives and

15 citizens of Ecuador, seek review of an October 24, 2023 decision of the BIA

16 affirming a December 21, 2022 decision of an Immigration Judge (“IJ”) denying

17 their application for asylum, withholding of removal, and relief under the

18 Convention Against Torture (“CAT”). In re Victor Gustavo Guaman-Parades, Gloria

19 Soraya Alvarado-Malla, Jeanpierre Nicolas Guaman-Alvarado, Nos. A 220 592

20 351/352/350 (B.I.A. Oct. 24, 2023), aff’g Nos. A 220 592 351/352/350 (Immigr. Ct.

21 N.Y.C. Dec. 21, 2022). We assume the parties’ familiarity with the underlying

22 facts and procedural history.

2 1 We review the IJ’s decision as modified by the BIA. See Xue Hong Yang v.

2 U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005). We review the agency’s fact-

3 finding “under the substantial evidence standard,” and we review questions of

4 law and the application of law to fact de novo. Hong Fei Gao v. Sessions, 891 F.3d

5 67, 76 (2d Cir. 2018). “[T]he administrative findings of fact are conclusive unless

6 any reasonable adjudicator would be compelled to conclude to the contrary.” 8

7 U.S.C. § 1252(b)(4)(B).

8 To establish eligibility for asylum, an applicant must prove that he “suffered

9 past persecution or . . . has a well-founded fear of future persecution.” 8 C.F.R.

10 § 1208.13(b). Similarly, an applicant for withholding of removal must establish

11 either past persecution or that he will “more likely than not” be persecuted in the

12 future. Id. § 1208.16(b)(1), (2). An applicant for asylum and withholding of

13 removal has the burden of showing that “race, religion, nationality, membership

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

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

16 §§ 1208.13(b), 1208.16(b); Quituizaca v. Garland, 52 F.4th 103, 105–06 (2d Cir. 2022)

17 (holding that “one central reason” standard applies to both asylum and

3 1 withholding). 1 Where, as here, applicants assert membership in a particular

2 social group, they have to show “both that the group itself was cognizable,” Paloka

3 v. Holder, 762 F.3d 191, 195 (2d Cir. 2014), and that their membership in the group

4 was or will be “one central reason” for the harm suffered or feared, Quituizaca, 52

5 F.4th at 105–06.

6 Before the IJ, Guaman-Parades asserted protected status as a member of the

7 particular social groups of Ecuadorian men who resisted recruitment by a gang

8 and Ecuadorian men who are targeted by a gang; Alvarado-Malla and their son

9 asserted membership in the group of family members of Guaman-Parades.

10 Before the BIA, Petitioners asserted membership in a particular social group of

11 “those who opposed criminal activity” or “witnesses [who] oppos[ed] criminal

12 activity.” Certified Admin. Rec. (“CAR”) at 15, 16. The BIA found the family-

13 based social group waived, declined to consider the new group raised on appeal

14 to the extent it differed from the groups identified before the IJ, then declined to

1 Petitioners argue here that the agency erred by failing to conduct an independent analysis of withholding of removal. That argument is unexhausted and thus not properly before us. See Punin v. Garland, 108 F.4th 114, 123–24 (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.”). Moreover, as set forth here, the “one central reason” requirement for asylum applies equally to withholding of removal. See Quituizaca, 52 F.4th at 105–06. 4 1 reach the cognizability of the groups proffered to the IJ, but affirmed the IJ’s

2 dispositive nexus determination.

3 Petitioners do not challenge those findings here, but instead reiterate the

4 argument they first raised before the BIA—that they identified and are members

5 of a cognizable group of witnesses who opposed criminal activity. “We consider

6 abandoned any claims not adequately presented in an appellant’s brief, and an

7 appellant’s failure to make legal or factual arguments constitutes abandonment.”

8 Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (quotation marks omitted). The

9 abandoned grounds—waiver of the family-based social group, and nexus between

10 the alleged harm and the social groups proposed before the IJ—are dispositive, so

11 there is nothing more for us to review regarding asylum and withholding of

12 removal. See Paloka, 762 F.3d at 195 (“To succeed on a particular social group

13 claim, the applicant must establish both that the group itself was cognizable, and

14 that the alleged persecutors targeted the applicant on account of her membership

15 in that group.” (citations and quotation marks omitted)).

16 With respect to the argument raised here, the BIA declined to reach the

17 proposed social group of “those who oppose criminal activity” because Petitioners

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Related

Silvana Paloka v. Eric H. Holder, Jr.
762 F.3d 191 (Second Circuit, 2014)
Quituizaca v. Garland
52 F.4th 103 (Second Circuit, 2022)
Prabhudial v. Holder
780 F.3d 553 (Second Circuit, 2015)
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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Guaman-Parades v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guaman-parades-v-bondi-ca2-2025.