Pedro Aguilar-Mejia v. Pamela Bondi

CourtCourt of Appeals for the Sixth Circuit
DecidedAugust 13, 2025
Docket22-3365
StatusUnpublished

This text of Pedro Aguilar-Mejia v. Pamela Bondi (Pedro Aguilar-Mejia v. Pamela Bondi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pedro Aguilar-Mejia v. Pamela Bondi, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0399n.06

Case No. 22-3365

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Aug 13, 2025 KELLY L. STEPHENS, Clerk ) PEDRO AGUILAR-MEJIA, ) Petitioner, ) ON PETITION FOR REVIEW OF ) THE DECISION OF THE BOARD v. ) OF IMMIGRATION APPEALS ) PAMELA BONDI, Attorney General, ) OPINION Respondent. ) )

Before: SUTTON; Chief Judge; SILER and WHITE, Circuit Judges.

SILER, Circuit Judge. Pedro Aguilar-Mejia, a native and citizen of Guatemala,

challenges the Board of Immigration Appeals’ (“BIA”) decision to affirm the denial of his requests

for asylum, withholding of removal, and protection under the Convention Against Torture

(“CAT”). He also contests the BIA’s refusal to remand for consideration of new evidence.

Because substantial evidence supports the agency’s disposition and the BIA acted within its broad

discretion in denying remand, we deny the petition for review.

I.

The facts are straightforward and, for the most part, uncontested. In 2013, when Aguilar-

Mejia was 15 years old, three Mara 18 gang members approached him as he was leaving a

neighborhood store in Guatemala. They slapped and pushed him, took the drink and small amount

of money he was carrying, and ordered him to join their gang. He refused. He suffered no lasting

injury, did not seek medical care, and on his parents’ advice made no police report. No. 22-3365, Aguilar-Mejia v. Bondi

Three days later, his family moved to another town, and Aguilar-Mejia testified that he

experienced no further threats or harm during the next 10 months before he left Guatemala. In

October 2014, Aguilar-Mejia entered the United States without admission or parole.

Removal proceedings followed. At a hearing in February 2015, he admitted the notice-to-

appear allegations, conceded removability, and indicated that he would seek asylum, withholding

of removal, and CAT protection. He filed a Form I-589 application a few months later.

At the December 2018 merits hearing, Aguilar-Mejia’s counsel claimed persecution as a

member of a proposed particular social group (“PSG”): “child victims” “of gang recruitment and

gang violence in Guatemala,” or, as stated in closing argument, “young . . . male Guatemalans.”

In April 2019, the Immigration Judge (“IJ”) found Aguilar-Mejia credible yet denied all relief,

holding that the single 2013 incident did not rise to persecution, lacked nexus to a protected ground,

and involved a PSG that was impermissibly circular and insufficiently particular.

Aguilar-Mejia appealed and, citing his girlfriend’s pregnancy, moved to remand so he

could present additional family-based PSG formulations. In March 2022, the BIA dismissed his

appeal and denied remand, echoing the IJ’s analysis and finding the new evidence immaterial.

Aguilar-Mejia timely petitioned this court for review.

II.

We review legal questions de novo and factual findings for substantial evidence, accepting

the agency’s view unless the record compels the opposite result. Tista-Ruiz de Ajualip v. Garland,

114 F.4th 487, 495 (6th Cir. 2024). Denial of a motion to remand receives abuse-of-discretion

review. Marqus v. Barr, 968 F.3d 583, 592 (6th Cir. 2020).

2 No. 22-3365, Aguilar-Mejia v. Bondi

III.

A. Asylum

An asylum applicant must show past persecution or a well-founded fear of future

persecution “on account of” one of five protected grounds, here, membership in a cognizable PSG.

8 U.S.C. §§ 1101(a)(42)(A); 1158(b)(1)(B)(i). Three questions capture the dispute: motivation,

magnitude, and group definition.

Motivation (nexus). Why did the gang target Aguilar-Mejia? The IJ concluded that Mara

18 confronted Aguilar-Mejia for ordinary criminal reasons—to take the few quetzales in his pocket

and to recruit him—not because of any protected characteristic. The record supports that view:

Aguilar-Mejia testified that the assailants robbed him of about 10 quetzales and told him that they

could “give [him] money” if he joined the gang. On cross-examination he agreed with counsel’s

statement that Mara 18 “rob[s] people of all ages” when it needs money. Such general economic

or criminal motives do not supply the “on account of” nexus that the INA demands. See

Khozhaynova v. Holder, 641 F.3d 187, 195 (6th Cir. 2011). Aguilar-Mejia’s opening brief devotes

only a single, conclusory sentence to contest the IJ’s nexus finding, which forfeits the argument.

See McPherson v. Kelsey, 125 F.3d 989, 995–96 (6th Cir. 1997).

Magnitude (persecution). Persecution “requires more than a few isolated incidents of

verbal harassment or intimidation.” Pilica v. Ashcroft, 388 F.3d 941, 950 (6th Cir. 2004) (citation

omitted). Aguilar-Mejia experienced just one brief encounter: the gang members slapped and

pushed him, stole roughly 10 quetzales, and attempted to recruit him. He sustained no lasting

injury, sought no medical care, and safely relocated within Guatemala where he lived for the next

10 months without further incident. A single, short-lived assault followed by successful relocation

falls well below the persecution threshold. See Mikhailevitch v. INS, 146 F.3d 384, 390 (6th Cir.

3 No. 22-3365, Aguilar-Mejia v. Bondi

1998); Rios-Zamora v. Sessions, 751 F. App’x 784, 787 (6th Cir. 2018) (a robbery that “is merely

an instance of ‘widespread crime and violence[]’ . . . does not constitute persecution” (quoting

Menijar v. Lynch, 812 F.3d 491, 501 (6th Cir. 2015))). The record does not compel a different

conclusion.

Group definition (PSG). A PSG must (i) share an immutable trait, (ii) be defined with

particularity, and (iii) be socially distinct in Guatemala. Cruz-Guzman v. Barr, 920 F.3d 1033,

1036 (6th Cir. 2019). “Child victims of gang recruitment and gang violence” fails two of the three

tests. It defines the group by the harm feared (circularity) and sweeps in an indeterminate slice of

Guatemalan youth (lack of particularity). Rreshpja v. Gonzales, 420 F.3d 551, 555–56 (6th Cir.

2005). Nor does “young male Guatemalans” fare better; broad demographic labels rarely do.

Lopez Garcia v. Garland, 2023 WL 4145320, at *5 (6th Cir. June 23, 2023).

Failure to prove even a single statutory prerequisite is fatal to an asylum application. See

Cruz-Guzman, 920 F.3d at 1038. Aguilar-Mejia misses all three.

B. Withholding of Removal

Withholding of removal is available only to an applicant who shows a “clear probability”

that his “life or freedom would be threatened” on account of a protected ground—meaning it is

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Related

Immigration & Naturalization Service v. Stevic
467 U.S. 407 (Supreme Court, 1984)
Mcpherson v. Kelsey
125 F.3d 989 (Sixth Circuit, 1997)
Sead Pilica v. John Ashcroft
388 F.3d 941 (Sixth Circuit, 2004)
Khozhaynova v. Holder
641 F.3d 187 (Sixth Circuit, 2011)
Wisam Yousif v. Loretta E. Lynch
796 F.3d 622 (Sixth Circuit, 2015)
Jose Zaldana Menijar v. Loretta Lynch
812 F.3d 491 (Sixth Circuit, 2015)
Jonathan Cruz-Guzman v. William P. Barr
920 F.3d 1033 (Sixth Circuit, 2019)
Ammar Marqus v. William P. Barr
968 F.3d 583 (Sixth Circuit, 2020)
Alma Delia Reyes Galeana v. Merrick B. Garland
94 F.4th 555 (Sixth Circuit, 2024)
Marta Tista-Ruiz de Ajualip v. Merrick B. Garland
114 F.4th 487 (Sixth Circuit, 2024)

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Pedro Aguilar-Mejia v. Pamela Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pedro-aguilar-mejia-v-pamela-bondi-ca6-2025.