Jose Ramos-Cruz v. Attorney General United States of America

CourtCourt of Appeals for the Third Circuit
DecidedOctober 1, 2024
Docket24-1104
StatusUnpublished

This text of Jose Ramos-Cruz v. Attorney General United States of America (Jose Ramos-Cruz v. Attorney General United States of America) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jose Ramos-Cruz v. Attorney General United States of America, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 24-1104

JOSE MANUEL RAMOS-CRUZ; BIANA AMERICA GIRON-BARRERA DE RAMOS; A. C. R.-G.; K. R. R.-G.,

Petitioners

v.

ATTORNEY GENERAL UNITED STATES OF AMERICA

On Petition for Review of an Order of the Board of Immigration Appeals (Agency Nos. A220-971-171; A220-971-172; A220-971-173 and A220-971-174) Immigration Judge: Honorable Jason L. Pope

Submitted Under Third Circuit L.A.R. 34.1(a) September 27, 2024

Before: KRAUSE, BIBAS and AMBRO, Circuit Judges

(Opinion filed: October 1, 2024) OPINION*

AMBRO, Circuit Judge

Jose Manuel Ramos-Cruz and his wife, Bianca America Giron-Barrera de Ramos,

along with their two minor children, seek review of an order of the Board of Immigration

Appeals (“BIA”) that dismissed their appeal of the decision by an Immigration Judge (“IJ”)

denying their applications for asylum, withholding of removal, and protection under the

Convention Against Torture (“CAT”). As Ramos-Cruz does not contest the denial of CAT

protection, and his other challenges fail, we deny the petition.

I

Ramos-Cruz is a native and citizen of Guatemala who entered the United States with

his wife and two daughters in June 2021 after “being extorted and threatened with death”

by unknown individuals whom he believed “were affiliated with organized crime.” 1

Administrative Record (“A.R”) 46-47. Five incidents prompted Ramos-Cruz and his

family to flee. In January that year, he received a phone call demanding that he pay $400

or else his daughters would be killed. The next month, four armed and masked individuals

*This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. 1 For simplicity, we refer only to Jose Manuel Ramos-Cruz, as he is the lead petitioner. His wife (who had previously entered the country in February 2021 but stayed only briefly) and their children sought asylum as derivative beneficiaries. They also filed independent applications for asylum, withholding of removal, and CAT protection, but the bases for those claims are the same as Ramos-Cruz’s. 2 came to his house, this time doubling their demands. Because Ramos-Cruz didn’t have the

means to pay, they asked that he instead join their group (which he did not do). He received

two additional threats (at least one in March), and once again the individuals warned that

he or his children would be killed. In May, “a man” attempted to kidnap Ramos-Cruz’s

younger daughter while the two were going to the store. A.R. 47. Though unsuccessful in

abducting the child, the individual threatened that Ramos-Cruz was “already … a dead

man.” Id. The latter immediately went to the police to report the attempted kidnapping

and prior threats of extortion but received an “[un]satisfactory response.” A.R. 48. Fearing

for his life and that of his family, he left for the United States the next day.

The Department of Homeland Security began removal proceedings in September

2021. Ramos-Cruz conceded removability but requested the relief already noted. As part

of his asylum and withholding-of-removal claims, he argued that the threats of extortion

and attempted kidnapping amounted to past persecution and gave rise to a well-founded

fear of future persecution based on his membership in two particular social groups

(“PSGs”): “family unit” and “individuals who publicly provide assistance to law

enforcement against criminals.” A.R. 56, 111-12.

The IJ denied the asylum application, concluding that the listed incidents did not

rise to the level of persecution, and, even if they did, those threats were not sufficiently tied

to the alleged PSGs. Addressing the family-unit PSG first, the IJ reasoned that the extortion

attempts were motivated by financial gain “rather than for any purpose in targeting the

respondents based on their membership in a family unit.” A.R. 56. And because the IJ

found it “unclear” what drove the attempted kidnapping, noting it could have “simply 3 [been] an isolated criminal act,” he concluded Ramos-Cruz did not sufficiently establish a

link (often referred to in legal terms as a nexus) between that incident and the family PSG

either. A.R. 57. Turning to the second PSG, the IJ initially remarked it was “not clear”

whether Ramos-Cruz fit the group of “individuals who publicly provide assistance to law

enforcement,” as the police complaint he made was private, and nothing in the record

suggested the individuals who threatened him knew he had filed it. A.R. 57. Moreover,

because he went to the police only after the extortion and kidnapping attempts, Ramos-

Cruz could not show he was targeted based on his membership in that PSG. Id. For similar

reasons, the IJ found he could not establish an objectively reasonable fear of future

persecution, making him ineligible for asylum and withholding of removal. Relief under

the CAT also failed.

The BIA dismissed Ramos-Cruz’s appeal. It discerned no clear error in the IJ’s

nexus determination, which was dispositive of the asylum and withholding claims, and also

affirmed Ramos-Cruz’s ineligibility for CAT protection. This petition for review followed.

II 2

Our task is quite narrow. Ramos-Cruz does not seek review of the denial of CAT

relief and thus has abandoned that claim. See Cortez-Amador v. Att’y Gen., 66 F.4th 429,

432 n.4 (3d Cir. 2023). And because the agency’s nexus finding, if supported by substantial

evidence, disposes of his remaining claims, we need not entertain the challenges to the IJ’s

2 Our jurisdiction lies under 8 U.S.C. § 1252(a). Because the BIA “invoke[d] specific aspects of the IJ’s analysis and factfinding” to support its conclusions, we review both decisions. Thayalan v. Att’y Gen., 997 F.3d 132, 137 (3d Cir. 2021) (citation omitted). 4 credibility determinations or his conclusion that the threats Ramos-Cruz experienced do

not amount to persecution.

To qualify for asylum, a petitioner must demonstrate “persecution or a well-founded

fear of persecution on account of” a statutorily protected ground—here, membership in a

PSG. 8 U.S.C. § 1101(a)(42)(A); § 1158(b)(1)(B)(i). That is the case “only if that ground

‘was or will be at least one central reason for persecuting the applicant.’” Thayalan v. Att’y

Gen., 997 F.3d 132, 138 (3d Cir. 2021) (quoting 8 U.S.C. § 1158(b)(1)(B)(i)). Asylum is

unavailable “when the characteristic at issue ‘played only an incidental, tangential, or

superficial role.’” Id. at 142 (quoting Gonzalez-Posadas v. Att’y Gen., 781 F.3d 677, 685

(3d Cir. 2015)).

Ramos-Cruz’s challenges to the IJ and BIA’s nexus findings are unavailing. We

agree that he cannot rely on the second PSG—putting aside whether he indeed is an

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