Mayra Lopez-Barrera v. Attorney General United States of America

CourtCourt of Appeals for the Third Circuit
DecidedApril 16, 2025
Docket24-2217
StatusUnpublished

This text of Mayra Lopez-Barrera v. Attorney General United States of America (Mayra Lopez-Barrera 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
Mayra Lopez-Barrera v. Attorney General United States of America, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 24-2217 _____________

MAYRA LOPEZ-BARRERA; A. A. S.-L., Petitioners

v.

ATTORNEY GENERAL UNITED STATES OF AMERICA

_____________

On Petition for Review of a Decision of the Board of Immigration Appeals (A220-452-749; A220-321-100) Immigration Judge: Jason L. Pope _____________

Submitted Under Third Circuit L.A.R. 34.1(a) March 10, 2025

Before: SHWARTZ, RESTREPO, and CHUNG, Circuit Judges

(Filed: April 16, 2025) _________

OPINION* _________

RESTREPO, Circuit Judge

* This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. Petitioners Mayra Lopez-Barrera and her child, citizens of Guatemala, sought

refuge in the United States from the domestic violence they suffered at the hands of the

child’s father. They filed for asylum, withholding of removal, and CAT protection1 after

the Department of Homeland Security initiated removal proceedings against them. The

immigration judge denied their applications, and the BIA2 affirmed that decision.

Although the immigration judge found Ms. Lopez-Barrera credible, he determined she

and her child could not establish that Guatemalan authorities were unable or unwilling to

protect them or that the harm they suffered rose to the level of torture necessary for CAT

protection. The BIA agreed on these two dispositive issues and affirmed. For the

reasons below, we will deny the petition for review of the BIA’s decision.

I. Background

During the removal proceedings, Ms. Lopez-Barrera and her child conceded

removability and applied for asylum, withholding of removal, and CAT protection. They

sought relief based on the threats and domestic violence they suffered at the hands of Ms.

Lopez-Barrera’s former partner, Alexander Tomas Sanchez Gonzales (“Sanchez”), who

is also the father of her child. The three lived together in Guatemala for about four and a

half years.

“CAT Protection” refers to protection under the regulations implementing the 1

Convention Against Torture. See 8 C.F.R §§ 1208.16(c)–1208.18. 2 “BIA” refers to the Board of Immigration Appeals. 2 In May 2020, Mr. Sanchez began physically abusing Ms. Lopez-Barrera, hitting

her with a belt on at least one occasion. Another time he hit her with a tree branch,

causing a wound that bled and took over a month to heal. Mr. Sanchez also physically

abused their child. In December 2020, Ms. Lopez-Barrera discovered Mr. Sanchez was

having an affair. A month later, she and her child moved out of their abuser’s home.

Around this time, Mr. Sanchez also began harassing Ms. Lopez-Barrera, hacking

her Facebook account and posting defamatory statements. Fed up with the harassment

and physical abuse, Ms. Lopez-Barrera filed a complaint with Guatemalan authorities in

January 2021 and obtained a six-month protective order against Mr. Sanchez. Still, Mr.

Sanchez continued harassing and threatening Ms. Lopez-Barrera in open violation of the

protective order. But Ms. Lopez-Barrera failed to report these violations or otherwise

seek enforcement of the restraining order.

In February, Ms. Lopez-Barrera spoke with the Guatemalan authorities again after

Mr. Sanchez threatened to take their child. Mr. Sanchez allegedly paid gang members to

threaten and extort Ms. Lopez-Barrera, though she never paid them or reported these

threats to authorities. In July, after the threats and extortion attempts continued, Ms.

Lopez-Barrera and her child fled Guatemala for the United States. Even after their

departure, the threats continued but were now directed at Ms. Lopez-Barrera’s siblings.

At her merits hearing before the immigration judge, Ms. Lopez-Barrera testified

that she did not pursue enforcement of the protective order because she believed doing so

would have been futile given Mr. Sanchez’s disregard of the law. While the immigration

3 judge found Mr. Lopez-Barrera credible and concluded that the harm she suffered rose to

the level of persecution, he determined that she failed to establish that Guatemalan

authorities were unable or unwilling to protect her.3 Finding this failure dispositive, the

immigration judge denied Ms. Lopez-Barrera and her child’s petitions and ordered them

removed.

The BIA affirmed, agreeing that Ms. Lopez-Barrera’s was not entitled to relief

because she did not show that Guatemalan authorities were unable or unwilling to control

her abuser. It noted that the Guatemalan government “extended protection” to Ms.

Lopez-Barrera “[t]o the extent [she] pursued and followed up on her complaints.” App.

4. Thus, the BIA concluded she could not establish eligibility for asylum, withholding of

removal, humanitarian asylum, or CAT protection.

II. Discussion

We have jurisdiction under 8 U.S.C. § 1252 and review the BIA’s factual findings4

for substantial evidence, giving them effect “unless any reasonable adjudicator would be

compelled to conclude to the contrary.” 8 U.S.C. §1252(b)(4)(B); see also Herrera-

3 The immigration judge also found that the persecution was not on account of a protected ground. 4 “Because the BIA issued its own opinion, we review its decision rather than that of the IJ. However, we also look to the decision of the IJ to the extent that the BIA defers to, or adopts, the IJ’s reasoning.” Patel v. Att’y Gen., 599 F.3d 295, 297 (3d Cir. 2010) (citing Li v. Att’y Gen., 400 F.3d 157, 162 (3d Cir. 2005); Chavarria v. Gonzalez, 446 F.3d 508, 515 (3d Cir. 2006)). 4 Reyes v. Att’y Gen., 952 F.3d 101, 106 (3d Cir. 2020). We review any legal issues de

novo. Herrera-Reyes, 952 F.3d at 106.

To qualify for asylum, an applicant must establish, among other things, either (1)

“past persecution on account of a protected ground, which creates a rebuttable

presumption of a well-founded fear of future persecution,” or (2) “a well-founded fear of

future persecution on account of a protected ground without regard to past persecution.”

Hernandez Garmendia v. Att’y Gen., 28 F.4th 476, 482 (3d Cir. 2022) (citing 8 C.F.R. §

1208.13(b)) (emphasis added). To obtain withholding of removal, the applicant must

“establish[] a ‘clear probability’ of persecution upon removal.” Saban-Cach v. Att’y

Gen., 58 F.4th 716, 724 (3d Cir. 2023). This requires consideration of whether the

applicant has “show[n] that it is more likely than not that s/he would be persecuted if

returned home. This analysis starts with the question of whether the petitioner can

establish past persecution.” Id. Thus, an applicant who cannot establish past persecution

for asylum purposes cannot meet the standard for withholding of removal either.

Thayalan v. Att’y Gen., 997 F.3d 132, 138 (3d Cir. 2021).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Mayra Lopez-Barrera v. Attorney General United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayra-lopez-barrera-v-attorney-general-united-states-of-america-ca3-2025.