Ovalle-Bamaca v. Blanche

CourtCourt of Appeals for the Ninth Circuit
DecidedApril 17, 2026
Docket25-3072
StatusUnpublished

This text of Ovalle-Bamaca v. Blanche (Ovalle-Bamaca 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
Ovalle-Bamaca v. Blanche, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 17 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

BIATO RODEL OVALLE-BAMACA, No. 25-3072 Agency No. Petitioner, A206-237-138 v. MEMORANDUM*

TODD BLANCHE, Acting Attorney General,

Respondent.

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

Submitted April 17, 2026** Portland, Oregon

Before: OWENS, VANDYKE, and SUNG, Circuit Judges. Concurrence by Judge VANDYKE.

Biato Rodel Ovalle-Bamaca petitions for review of the Board of

Immigration Appeals’ (“BIA’s”) decision affirming an Immigration Judge’s

(“IJ’s”) decision denying his applications for cancellation of removal, asylum,

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). withholding of removal, and protection under the Convention Against Torture

(“CAT”). We have jurisdiction under 8 U.S.C. § 1252. We review legal questions

de novo, Gonzalez-Caraveo v. Sessions, 882 F.3d 885, 893 (9th Cir. 2018), and

factual determinations and “fact-intensive mixed questions” for substantial

evidence, Ruiz v. Bondi, 163 F.4th 586, 592, 599 (9th Cir. 2025) (citation omitted).

We deny the petition.

1. The agency did not err in concluding that Ovalle-Bamaca is ineligible

for cancellation of removal for failing to demonstrate “exceptional and extremely

unusual hardship” to a qualifying family member. See Gonzalez-Juarez v. Bondi,

137 F.4th 996, 999 (9th Cir. 2025) (applicant must demonstrate “that removal

would result in exceptional and extremely unusual hardship to the alien’s spouse,

parent, or child, who is a citizen of the United States or an alien lawfully admitted

for permanent residence” (quoting 8 U.S.C. § 1229b(b)(1))). The agency’s

“exceptional and extremely unusual hardship” determination is a mixed question

we review for substantial evidence. Id. at 1003. The BIA concluded that the

hardship Ovalle-Bamaca’s qualifying minor children would face that would result

from relocating to Guatemala and being uprooted from their schools and

community, although “significant and possibly extreme,” is “neither . . .

exceptional nor unusual.” Substantial evidence supports this determination. See

id. at 1007–08 (hardship to minor children resulting from relocation to Mexico,

2 25-3072 where they could face “high levels of crime and violence,” “lost educational

opportunities,” difficulty due to “lack of fluency in Spanish,” and “separation from

their older sister” in the United States, was not “exceptional” or “extremely

unusual” hardship because such hardship is present in “a large proportion of

removal cases”).

2. The agency did not err in finding that Ovalle-Bamaca’s application for

asylum was untimely and ineligible for an exception to the one-year filing rule

based on “changed circumstances” in Guatemala.

First, we have jurisdiction to review the agency’s “changed circumstances”

determination because it presents a mixed question of fact and law. Under

§ 1158(a)(2)(D), the agency may consider an untimely asylum application if the

applicant “demonstrates to the satisfaction of the Attorney General either the

existence of changed circumstances which materially affect the applicant’s

eligibility for asylum or extraordinary circumstances relating to the delay in filing

an application.” 8 U.S.C. § 1158(a)(2)(D). In Ruiz, we held that the

“extraordinary circumstances” exception under the same statutory provision

presents a mixed question of law and fact that we have jurisdiction to review. 163

F.4th at 599. Because the “changed circumstances” and “extraordinary

circumstances” provisions are “parallel” and “analogous” exceptions provided for

in the same statute, Husyev v. Mukasey, 528 F.3d 1172, 1178, 1180 (9th Cir. 2008),

3 25-3072 abrogated on other grounds by Ruiz, 163 F.4th at 593, the reasoning of Ruiz

applies equally here.

On the merits, substantial evidence supports the agency’s determination that

Ovalle-Bamaca failed to demonstrate changed circumstances. Ovalle-Bamaca

argued that, since he left Guatemala in 1995, Guatemala has fallen under the

control of a mafia and “threats [were] made against his father in Guatemala”

beginning in November 2017. The IJ determined that Ovalle-Bamaca failed to

present sufficient evidence that a mafia controls Guatemala. The BIA agreed

without additional analysis. Accordingly, “we review the decisions of both the

BIA and the IJ to the extent that the BIA agreed with the IJ’s conclusions.”

Manzano v. Garland, 104 F.4th 1202, 1206 (9th Cir. 2024) (citation modified).

Here, the record does not “compel[] a contrary conclusion.” Duran-Rodriguez v.

Barr, 918 F.3d 1025, 1028 (9th Cir. 2019).

3. The agency did not err in denying Ovalle-Bamaca’s claim for

withholding of removal on the ground that he failed to administratively exhaust the

claim. An applicant’s failure to raise an issue to the BIA generally constitutes a

failure to exhaust. See Iraheta-Martinez v. Garland, 12 F.4th 942, 948 (9th Cir.

2021); 8 U.S.C. § 1252(d)(1). Ovalle-Bamaca argues that he adequately raised the

issue in his appeal to the BIA because he stated in his notice of appeal: “[Ovalle-

Bamaca] appeals the immigration judge’s denial of his application for withholding

4 25-3072 of removal, as [Ovalle-Bamaca] met his burden to prove a clear probability that he

will suffer future persecution if removed to Guatemala.” This cursory statement

was not “sufficient to put the BIA on notice of what was being challenged.” Bare

v. Barr, 975 F.3d 952, 960 (9th Cir. 2020) (a general, nonspecific challenge is

insufficient). Ovalle-Bamaca further argues that the BIA adopted the IJ’s entire

decision because it cited Matter of Burbano, 20 I. & N. Dec. 872 (BIA 1994), and

it therefore adequately considered his withholding argument. See Mutuku v.

Holder, 600 F.3d 1210, 1213 (9th Cir. 2010) (issue is properly exhausted when it

was presented to the IJ, and the BIA affirmed citing Matter of Burbano). But here,

the BIA “constrict[ed] the scope” of its adoption of the IJ’s decision by

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

Related

Mutuku v. Holder
600 F.3d 1210 (Ninth Circuit, 2010)
Cole v. Holder
659 F.3d 762 (Ninth Circuit, 2011)
Husyev v. Mukasey
528 F.3d 1172 (Ninth Circuit, 2008)
Jose Gonzalez-Caraveo v. Jefferson Sessions
882 F.3d 885 (Ninth Circuit, 2018)
Jose Duran-Rodriguez v. William Barr
918 F.3d 1025 (Ninth Circuit, 2019)
Ibrahim Bare v. William Barr
975 F.3d 952 (Ninth Circuit, 2020)
Santos Iraheta-Martinez v. Merrick Garland
12 F.4th 942 (Ninth Circuit, 2021)
BURBANO
20 I. & N. Dec. 872 (Board of Immigration Appeals, 1994)
Alfaro Manzano v. Garland
104 F.4th 1202 (Ninth Circuit, 2024)
Gonzalez-Juarez v. Bondi
137 F.4th 996 (Ninth Circuit, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
Ovalle-Bamaca v. Blanche, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ovalle-bamaca-v-blanche-ca9-2026.