Martinez-Hernandez v. Blanche

CourtCourt of Appeals for the Ninth Circuit
DecidedJuly 9, 2026
Docket24-2966
StatusUnpublished

This text of Martinez-Hernandez v. Blanche (Martinez-Hernandez v. Blanche) 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
Martinez-Hernandez v. Blanche, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 9 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

DANIEL SOLOMAN MARTINEZ- No. 24-2966 HERNANDEZ, Agency No. A216-644-998 Petitioner,

v. MEMORANDUM*

TODD BLANCHE, Acting Attorney General,

Respondent.

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

Argued and Submitted June 26, 2026 San Francisco, California

Before: MURGUIA, Chief Judge, and KOH and H.A. THOMAS, Circuit Judges.

Daniel Soloman Martinez-Hernandez, a native and citizen of Guatemala,

petitions for review of the Board of Immigration Appeals’ (“BIA”) decision

affirming the Immigration Judge’s (“IJ”) denial of his applications for asylum,

withholding of removal, and protection under the Convention Against Torture

(“CAT”). Where the BIA conducted a de novo review of the IJ’s decision, “our

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. review is limited to the BIA’s decision except to the extent that the IJ’s opinion is

expressly adopted by the BIA.” Garcia v. Wilkinson, 988 F.3d 1136, 1142 (9th Cir.

2021) (citation modified). “We review purely legal questions de novo, and the

agency’s factual findings for substantial evidence.” Perez-Portillo v. Garland, 56

F.4th 788, 792 (9th Cir. 2022). We have jurisdiction under 8 U.S.C. § 1252. We

deny the petition.

1. The BIA did not abuse its discretion by finding no evidence in the record

that Martinez-Hernandez was incompetent. See Lemus-Escobar v. Bondi, 158 F.4th

944, 955 (9th Cir. 2025). “A petitioner is presumed to be competent and, absent

indicia of mental incompetency, an [IJ] is under no obligation to analyze a

petitioner’s competency.” Id. (citation modified). The record in this case does not

reflect that Martinez-Hernandez exhibited “an inability to understand questions” or

“a high level of distraction;” nor does the record contain any “evidence of mental

illness or incompetency.” Id. To the contrary, Martinez-Hernandez had “a rational

and factual understanding of the nature and object of the proceedings.” Salgado v.

Sessions, 889 F.3d 982, 987 (9th Cir. 2018) (quoting Matter of M-A-M-, 25 I. & N.

Dec. 474, 474 (BIA 2011)). He recognized that the government had the burden to

prove his removability and testified consistently with his written application about

his fear of returning to Guatemala. On the isolated occasions that Martinez-

Hernandez began answering questions with unresponsive information, he answered

2 24-2966 coherently after the questions were repeated or rephrased. Because there were no

indications that Martinez-Hernandez was incompetent, the IJ was not required to

“make further inquiry.” Id. (quoting Matter of M-A-M-, 25 I. & N. Dec. at 474).

2. The BIA properly found that Martinez-Hernandez waived his challenge to

the IJ’s finding that his asylum application was untimely. See Alanniz v. Barr, 924

F.3d 1061, 1068–69 (9th Cir. 2019) (reviewing de novo the BIA’s determination

that issue was waived); see also 8 U.S.C. § 1158(a)(2)(B). “[T]he BIA is entitled to

look to the brief for an explication of the issues that petitioner is presenting to have

reviewed.” Abebe v. Mukasey, 554 F.3d 1203, 1208 (9th Cir. 2009) (en banc).

Martinez-Hernandez’s vague assertions of “blows to the head” and “mental health

issues” in his pro se brief to the BIA failed to alert the BIA that he was arguing

extraordinary circumstances excusing his untimely asylum application. See 8

U.S.C. § 1158(a)(2)(D); 8 C.F.R. § 1208.4(a)(5)(i), (ii).

3. The BIA did not abuse its discretion in concluding that Martinez-

Hernandez’s conviction for felony injury to a child under Idaho state law

constituted a particularly serious crime, rendering him ineligible for withholding of

removal.1 See Hernandez v. Garland, 52 F.4th 757, 765 (9th Cir. 2022). The BIA

1 Although Martinez-Hernandez did not challenge the merits of the IJ’s particularly serious crime determination before the BIA, this issue is properly before us because the BIA addressed it on the merits. See Parada v. Sessions, 902 F.3d 901, 914 (9th Cir. 2018) (“[W]e may review any issue addressed on the merits by the BIA, regardless of whether the petitioner raised it before the agency.”).

3 24-2966 “relied on the appropriate factors and proper evidence to reach [its] conclusion.”

Bare v. Barr, 975 F.3d 952, 961 (9th Cir. 2020) (citation modified). With respect

to the first factor—the nature of the conviction—Martinez-Hernandez does not

dispute that “the elements of the crime of conviction potentially bring the crime

into a category of particularly serious crimes.” Mendoza-Garcia v. Garland, 36

F.4th 989, 999 (9th Cir. 2022) (citation modified).

The BIA also considered “reliable information” in evaluating the second and

third factors: “the type of sentence imposed” and “the circumstances and

underlying facts of the conviction.” Bare, 975 F.3d at 961–62 (quoting In re N-A-

M-, 24 I. & N. Dec. 336, 342 (BIA 2007)). The BIA did not err by failing to

discuss evidence Martinez-Hernandez describes as “exculpatory.” Martinez-

Hernandez’s plea pursuant to North Carolina v. Alford, 400 U.S. 25 (1970), though

not an admission of guilt, is an admission that “sufficient evidence exist[ed] with

which the prosecution could establish its case.” State v. Goullette, 550 P.3d 277,

281 (Idaho 2024) (quoting State v. Easley, 322 P.3d 296, 299 n.1 (Idaho 2014)).

And Martinez-Hernandez’s vague testimony that he “didn’t do it” was not

particularly probative of “what [he] actually did.” Guerrero v. Whitaker, 908 F.3d

541, 545 (9th Cir. 2018). Nor did the BIA err by relying on the criminal complaint.

See Anaya-Ortiz v. Holder, 594 F.3d 673, 678 (9th Cir. 2010) (“[N]othing in the

language of the ‘particularly serious crime’ provisions . . . limits the scope of

4 24-2966 permissible evidence.”); see also Hernandez, 52 F.4th at 766 (explaining that

government-prepared documents are entitled to presumption of reliability).

We agree with the government that Martinez-Hernandez failed to exhaust

his procedural due process argument that the IJ improperly relied on hearsay in the

probable cause affidavit without providing him a reasonable opportunity to cross-

examine the arresting officer and the victim. See Tall v. Mukasey, 517 F.3d 1115,

1120 (9th Cir.

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Abebe v. Mukasey
554 F.3d 1203 (Ninth Circuit, 2009)
Anaya-Ortiz v. Holder
594 F.3d 673 (Ninth Circuit, 2010)
Tall v. Mukasey
517 F.3d 1115 (Ninth Circuit, 2008)
State v. Krystal Lynn Easley
322 P.3d 296 (Idaho Supreme Court, 2014)
Bistermu Mora Salgado v. Jefferson Sessions
889 F.3d 982 (Ninth Circuit, 2018)
Moris Quiroz Parada v. Jefferson Sessions, III
902 F.3d 901 (Ninth Circuit, 2018)
Danilo Mairena v. William Barr
917 F.3d 1119 (Ninth Circuit, 2019)
Jose Duran-Rodriguez v. William Barr
918 F.3d 1025 (Ninth Circuit, 2019)
Jose Alanniz v. William Barr
924 F.3d 1061 (Ninth Circuit, 2019)
Ibrahim Bare v. William Barr
975 F.3d 952 (Ninth Circuit, 2020)
Alicia Naranjo Garcia v. Robert Wilkinson
988 F.3d 1136 (Ninth Circuit, 2021)
M-A-M
25 I. & N. Dec. 474 (Board of Immigration Appeals, 2011)
N-A-M
24 I. & N. Dec. 336 (Board of Immigration Appeals, 2007)
Diego Mendoza-Garcia v. Merrick Garland
36 F.4th 989 (Ninth Circuit, 2022)

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