Maria Murudumbay-Tamay v. Todd Blanche

Court of Appeals for the Fourth Circuit·Decided July 20, 2026·No. 25-2011·Unpublished

Opinion

USCA4 Appeal: 25-2011 Doc: 20 Filed: 07/20/2026 Pg: 1 of 3

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-2011

MARIA NARCISA MURUDUMBAY-TAMAY; J.N.H.M.; C.D.H.M.; J.R.H.M.,

Petitioners,

v.

TODD BLANCHE, Acting Attorney General,

Respondent.

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

Submitted: July 16, 2026 Decided: July 20, 2026

Before WILKINSON, RICHARDSON, and QUATTLEBAUM, Circuit Judges.

Petition denied by unpublished per curiam opinion.

ON BRIEF: Anna A. Tijerina, Daniel I. Smulow, GRIFFITH IMMIGRATION LAW, Baltimore, Maryland, for Petitioners. John Shumate, Assistant Attorney General, Lisa M. Arnold, Senior Litigation Counsel, Deitz P. Lefort, Office of Immigration Litigation, Civil Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-2011 Doc: 20 Filed: 07/20/2026 Pg: 2 of 3

PER CURIAM:

Maria Narcisa Murudumbay-Tamay and her minor children, natives and citizens of

Ecuador, petition for review of an order of the Board of Immigration Appeals (Board)

dismissing their appeal from the immigration judge’s decision denying Murudumbay-

Tamay’s applications 1 for asylum and withholding of removal. 2 We deny the petition for

review.

The Board first rejected Murudumbay-Tamay’s argument that the immigration

judge failed to adequately develop the record, a ruling that Murudumbay-Tamay does not

challenge here. The Board also held that Murudumbay-Tamay waived review of the

immigration judge’s dispositive ruling—to wit: that Murudumbay-Tamay failed to

establish the requisite nexus between the past harm she alleged, and future harm she feared,

and any of the assumed-cognizable particular social groups, see Portillo Flores v. Garland,

3 F.4th 615, 626, 630-31 (4th Cir. 2021) (en banc) (discussing the three elements of an

asylum claim, particularly that the applicant must prove a nexus between the alleged

persecutory conduct and a protected ground)—by failing to specifically address that aspect

of the immigration judge’s ruling in her administrative appeal brief. Because this ruling

1 Murudumbay-Tamay’s minor children were riders on her asylum application, see 8 U.S.C. § 1158(b)(3), and are identified as petitioners in this court by their initials. 2 Murudumbay-Tamay has forfeited review of the immigration judge’s denial of relief under the Convention Against Torture, which was not challenged in the administrative appeal, by not raising that issue in the brief submitted to this court. See Fed. R. App. P. 28(a)(8)(A); Ullah v. Garland, 72 F.4th 597, 602 (4th Cir. 2023) (explaining that a party forfeits appellate review of those issues and claims not raised in the party’s briefs).

2 USCA4 Appeal: 25-2011 Doc: 20 Filed: 07/20/2026 Pg: 3 of 3

was dispositive of the applications for asylum and withholding of removal, the Board

affirmed the immigration judge’s denial of relief on this basis.

In this court, Murudumbay-Tamay contends that she did in fact raise the “no-nexus”

holding before the Board and, thus, that remand is necessary. However, review of the

record does not bear this out, and we discern no error in the Board’s application of its

procedural waiver rule in this context. See In re D-G-C-, 28 I. & N. Dec. 297, 297 n.1

(B.I.A. 2021) (explaining Board’s procedural rule that issues an applicant does “not

meaningfully challenge[]” on appeal will be deemed waived). Accordingly, we deny

Murudumbay-Tamay’s request for agency remand and deny the petition for review. See

In re Murudumbay-Tamay (B.I.A. Aug. 7, 2025).

We dispense with oral argument because the facts and legal contentions are

adequately presented in the materials before this court and argument would not aid the

decisional process.

PETITION DENIED

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Related

Hernan Portillo-Flores v. Merrick Garland
3 F.4th 615 (Fourth Circuit, 2021)
D-G-C
28 I. & N. Dec. 297 (Board of Immigration Appeals, 2021)
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72 F.4th 597 (Fourth Circuit, 2023)