Guillen v. Blanche

CourtCourt of Appeals for the Second Circuit
DecidedMay 28, 2026
Docket24-3118
StatusUnpublished

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

Opinion

24-3118 Funez-Guillen v. Blanche BIA A240 479 255/256

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.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 28th day of May, two thousand twenty- six.

PRESENT: PIERRE N. LEVAL, RAYMOND J. LOHIER, JR., SARAH A. L. MERRIAM, Circuit Judges. _____________________________________

JENNIFER ANDREA FUNEZ-GUILLEN, C.A.B.-F., 1 Petitioners,

v. 24-3118 NAC TODD BLANCHE, ACTING UNITED

1 We use only initials to refer to the minor petitioner in this publicly accessible order. STATES ATTORNEY GENERAL, 2 Respondent. _____________________________________

FOR PETITIONERS: Lilin M. Ciccarone, CMA Law Group, PLLC, Glen Cove, NY.

FOR RESPONDENT: Brett Shumate, Assistant Attorney General; Sheri R. Glaser, Acting Assistant Director; Peter Gannon, Trial Attorney, Office of Immigration Litigation, United States Department of Justice, Washington, DC.

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

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

DECREED that the petition for review is DENIED.

Jennifer Andrea Funez-Guillen and her minor child, natives and citizens of

Honduras, seek review of a November 4, 2024, decision of the BIA denying their

motion to reopen removal proceedings. See In re Jennifer Andrea Funez-Guillen,

Nos. A A240 479 255/256 (B.I.A. Nov. 4, 2024). We assume the parties’ familiarity

with the underlying facts and procedural history.

“We review a BIA decision to deny reopening deferentially for abuse of

2Pursuant to Federal Rule of Appellate Procedure 43(c)(2), Acting Attorney General Todd Blanche is automatically substituted for former Attorney General Pamela Bondi as Respondent.

2 discretion.” Jian Hui Shao v. Mukasey, 546 F.3d 138, 168–69 (2d Cir. 2008).

However, “we review de novo constitutional claims and questions of law.” Luna

v. Holder, 637 F.3d 85, 102 (2d Cir. 2011).

Where, as here, a movant seeks reopening to apply for asylum and

withholding of removal 3 more than 90 days after the final administrative order,

the BIA may deny the motion as untimely if the movant fails to establish a material

change in country conditions, or it may deny the motion if the movant has not met

her burden of showing that new evidence would change the outcome of the

proceedings. See 8 U.S.C. §§ 1229a(c)(7)(C)(i)–(ii) (setting 90-day deadline and

changed conditions exception); INS v. Abudu, 485 U.S. 94, 104 (1988) (holding that

the failure to establish “a prima facie case for the underlying substantive relief

sought” is an “independent ground[] on which the BIA may deny a motion to

reopen”); Jian Hui Shao, 546 F.3d at 168 (explaining that the burden is on the

movant to show “that the proffered new evidence would likely alter the result in

her case”). The BIA did not abuse its discretion in finding that Funez-Guillen

failed to establish prima facie eligibility for the relief sought.

3 Neither Funez-Guillen’s motion to reopen nor her brief here presses a claim for reopening to apply for relief under the Convention Against Torture.

3 First, contrary to her allegations here, Funez-Guillen did not submit country

conditions evidence in connection with her motion to reopen showing an increase

in violence in Honduras or the targeting of family members of gang affiliates

generally. The BIA acknowledged her fear of persecution premised on her newly

articulated social group (family of gang members), but concluded that a fear of

gang recruitment and violence generally does not constitute a basis for asylum or

withholding of removal.

Second, Funez-Guillen does not address the other elements of prima facie

eligibility; specifically, she does not challenge the BIA’s conclusion that she did

not establish a nexus to a protected ground even considering her new group.

Accordingly, she has abandoned a dispositive ground for the BIA’s denial of

reopening. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (“We consider

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

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

(quotation marks omitted)); Paloka v. Holder, 762 F.3d 191, 195–97 (2d Cir. 2014)

(requiring an applicant for asylum and withholding of removal based on

membership in a particular social group to show both a cognizable group and a

4 nexus between group membership and the harm feared).

Third, we agree with the BIA’s conclusion that a fear of gang violence and

recruitment lacks nexus to the asserted protected ground. Evidence that a gang

has general criminal motives, like recruitment, undercuts a claim of nexus to a

protected ground. See, e.g., Quituizaca v. Garland, 52 F.4th 103, 114–15 (2d Cir. 2022)

(rejecting a claim that ethnicity motivated robberies by gang members). “[W]hile

certain segments of a population may be more susceptible to one type of [gang]

criminal activity than another, where the residents all generally suffer from the

gang’s criminal efforts to sustain its enterprise, the significant societal problems

that result may not support relief in the form of asylum or withholding of

removal.” Quintanilla-Mejia v. Garland, 3 F.4th 569, 590 (2d Cir. 2021) (quotation

marks omitted); Matter of Acosta, 19 I. & N. Dec. 211, 222 (B.I.A. 1985) (explaining

that persecution is harm inflicted to “punish” a person “for possessing a belief or

characteristic a persecutor sought to overcome”). Here, nothing submitted in

connection with Funez-Guillen’s motion to reopen reveals that the gang saw her

as possessing a belief or characteristic to overcome; rather, her sister’s statement

that the gang wanted to recruit her shows that the gang simply wanted Funez-

5 Guillen to join its criminal activities. See Quituizaca, 52 F.4th at 114–15; cf. Matter

of Acosta, 19 I. & N. Dec. at 222. Nor did the threat reveal that the gang targeted

her because of her family membership, rather than because she was an available

target. See Yueqing Zhang v.

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Related

Jian Hui Shao v. Mukasey
546 F.3d 138 (Second Circuit, 2008)
Immigration & Naturalization Service v. Abudu
485 U.S. 94 (Supreme Court, 1988)
Luna v. Holder
637 F.3d 85 (Second Circuit, 2011)
Silvana Paloka v. Eric H. Holder, Jr.
762 F.3d 191 (Second Circuit, 2014)
Quintanilla v. Garland
3 F.4th 569 (Second Circuit, 2021)
LOZADA
19 I. & N. Dec. 637 (Board of Immigration Appeals, 1988)
ACOSTA
19 I. & N. Dec. 211 (Board of Immigration Appeals, 1985)
Quituizaca v. Garland
52 F.4th 103 (Second Circuit, 2022)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Paucar v. Garland
84 F.4th 71 (Second Circuit, 2023)

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Guillen v. Blanche, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guillen-v-blanche-ca2-2026.