Ramos-Hernandez v. Bondi

CourtCourt of Appeals for the First Circuit
DecidedDecember 22, 2025
Docket25-1038
StatusPublished

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

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Ramos-Hernandez v. Bondi, (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 25-1038

EDWIN DAVID RAMOS-HERNANDEZ; SHEYLY CRISTABEL LOPEZ; D.Z.R.L.,

Petitioners,

v.

PAMELA J. BONDI, Attorney General,

Respondent.

PETITION FOR REVIEW OF AN ORDER OF THE BOARD OF IMMIGRATION APPEALS

Before

Rikelman, Lynch, and Howard, Circuit Judges.

Kevin P. MacMurray and MacMurray & Associates on brief for petitioners.

Lindsay Marshall, Trial Attorney, U.S. Department of Justice, Civil Division, Office of Immigration Litigation, Brett A. Shumate, Assistant Attorney General, Civil Division, and Stephen J. Flynn, Assistant Director, Office of Immigration Litigation, on brief for respondent.

December 22, 2025 LYNCH, Circuit Judge. Edwin David Ramos-Hernandez, his

wife Sheyly Cristabel Lopez, and their minor daughter D.Z.R.L.

petition for review of a December 11, 2024, decision of the Board

of Immigration Appeals ("BIA"), which affirmed an Immigration

Judge's ("IJ") order denying their applications for asylum,

withholding of removal, and protection under the Convention

Against Torture ("CAT"). See 8 U.S.C. §§ 1158(b)(1)(A),

1231(b)(3)(A); 8 C.F.R. § 1208.16. We deny the petition and

explain why the agency's ruling was supported by substantial

evidence and committed no error of law.

I.

A.

Ramos-Hernandez, Lopez, and D.Z.R.L. are citizens of

Guatemala who entered the United States on September 8, 2021. On

October 20, 2021, the Department of Homeland Security served them

with Notices to Appear, charging them with removability pursuant

to § 212(a)(6)(A)(i) of the Immigration and Nationality Act

("INA"). On August 4, 2022, Ramos-Hernandez and Lopez filed

applications for asylum, withholding of removal, and relief under

the CAT, naming their daughter as a derivative beneficiary.

D.Z.R.L. also submitted her own applications for the same relief.

Ramos-Hernandez and Lopez both testified before the IJ

at a merits hearing on July 24, 2024. The IJ recounted the record

evidence, which included some inconsistencies, but nevertheless

- 2 - found the petitioners to be credible. However, the IJ concluded

the petitioners had not met their burdens as to any claims for

relief.

We describe the facts as found by the IJ, noting where

there are inconsistencies in the record. Lopez completed high

school and earned a teaching certification in Guatemala. She

found it difficult to secure employment, in part because she had

lost a finger in a childhood accident. When she was about eighteen

years old, she began working at her uncle's hardware store. In

2018, her uncle retired and sold the store to Lopez and her partner

Ramos-Hernandez, whom she had begun dating.

Around 2019, Lopez received a text message from an

unknown number demanding payment if she wished to continue

operating the store. The petitioners later received a note again

demanding payment. Ramos-Hernandez was also attacked while riding

his motorcycle, although the date of the incident is unclear from

the record.1 Unknown assailants hit him with a tree branch from

behind, knocked him to the ground unconscious, and beat him.

Emergency services were called, and he chose to recover at his

mother's home because he had never been to a doctor or hospital

1 A declaration from Ramos-Hernandez's mother, as well as police and ambulance reports in the record, indicate the attack occurred on November 26, 2019. However, Lopez's declaration stated the attack occurred approximately "[t]en months before the threats began" in 2019 (emphasis added).

- 3 - and feared being extorted.

In the face of these demands, the petitioners kept their

store open only on a reduced schedule before eventually closing it

in approximately 2019. They testified that they are concerned

about increased criminality in Guatemala and about the safety of

their children.

B.

On July 24, 2024, the IJ denied the petitioners'

applications for relief and protection on all grounds.

Regarding the asylum claims, the IJ found the

petitioners had failed to establish either past persecution or a

well founded fear of future persecution on account of a statutorily

protected ground. See 8 U.S.C. § 1101(a)(42)(A); 8 C.F.R.

§ 1208.13(b)(1). As to past persecution, the IJ held that the

record established only "sporadic mistreatment on a couple of

isolated events." As to a well founded fear of future persecution,

the IJ concluded that there was no reasonable possibility the

petitioners would be singled out again, because they had closed

their business and had not faced any threats unrelated to it.

Further, the IJ determined that the petitioners had not established

they could not reasonably and safely relocate internally within

Guatemala: they lived at home for approximately two years after

closing their business without incident, they did not explain how

their extorters may find them if they moved within Guatemala, and

- 4 - they did not know the identities of their extorters.

The IJ also did not find a nexus between the harm the

petitioners suffered and their proposed particular social groups

(PSGs): "Guatemalan small business owners" and the

"Lopez-Ramos-Hernandez nuclear family." The "small business

owners" proposed PSG was not cognizable, the IJ held, because it

lacked immutability and particularity. The IJ noted that

"business ownership can change without impacting identity" and

that the petitioners' proposed group, "which seemingly includes

all small business owners [in Guatemala] of many ages and

backgrounds," was vaguely defined. As to the "nuclear family"

proposed PSG, the IJ noted that "[n]exus is not established simply

because a particular social group of family members exists and the

family members experienced harm" and found that "[t]he evidence

does not show that the [petitioners'] familial relationship to the

Lopez-Ramos-Hernandez nuclear family was at the root of the harm

they experienced." To the extent that the petitioners also argued

that they were targeted based on their anti-gang political opinion,

the IJ concluded that there was insufficient evidence to suggest

that they had ever expressed such a political view in public, or

that the alleged harm was perpetrated by a purported gang.

Having found that the petitioners did not "clear the

lower hurdle for asylum," the IJ found that the petitioners

"necessarily fail[ed] to meet the higher bar for withholding of

- 5 - removal," which requires a "clear probability of persecution."

Finally, the IJ denied the petitioners' CAT claims, finding that

they did not present a compelling reason as to why they could not

relocate, their past experiences did not amount to torture, and

the evidence did not establish that they would face a

particularized risk of government-sanctioned torture upon their

return to Guatemala.

On October 16, 2024, the petitioners timely appealed the

IJ's decision to the BIA. On December 11, 2024, the BIA affirmed

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