Reyes-Robles v. Bondi

CourtCourt of Appeals for the Ninth Circuit
DecidedMarch 3, 2026
Docket24-1378
StatusUnpublished

This text of Reyes-Robles v. Bondi (Reyes-Robles v. Bondi) 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
Reyes-Robles v. Bondi, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 3 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

ALONDRA REYES-ROBLES, et al., No. 24-1378 Agency Nos. Petitioners, A246-254-678 A246-254-679 v. A246-254-680 A246-254-681 PAMELA BONDI, Attorney General, A246-254-683 A246-254-682 Respondent.

MEMORANDUM*

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

Submitted February 26, 2026** Spokane, Washington

Before: SUNG, H.A. THOMAS, and MENDOZA, Circuit Judges.

Lead Petitioner Alondra Reyes-Robles, her husband Rigoberto Martinez-

Grande, and their four children petition for review of the Board of Immigration

Appeals’ (“BIA’s”) order affirming the Immigration Judge’s (“IJ’s”) order denying

* 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). their applications for asylum, withholding of removal, and protection under the

Convention Against Torture (“CAT”).1 Where, as here, the BIA affirms the IJ’s

decision without adding any commentary of its own, we treat the IJ’s decision as

that of the BIA. See Sinha v. Holder, 564 F.3d 1015, 1019–20 (9th Cir. 2009).

“We review factual findings for substantial evidence and legal questions de novo.”

Flores Molina v. Garland, 37 F.4th 626, 632 (9th Cir. 2022) (quoting Guerra v.

Barr, 974 F.3d 909, 911 (9th Cir. 2020)). We have jurisdiction under 8 U.S.C.

§ 1252, and we deny the petition.

1. Petitioners appeal the agency’s determination that Reyes-Robles did

not establish past persecution. In their view, the record demonstrates that Reyes-

Robles experienced past persecution, based on (1) anonymous and threatening

phone calls that Reyes-Robles and Martinez-Grande received in late 2022 and

early 2023, (2) the death of Reyes-Robles’s former husband Nicolas in September

2020, and (3) men shooting at Petitioners’ house after Petitioners had left for the

United States.

It is unclear under our precedent whether we review past-persecution

determinations using a de novo or substantial-evidence standard of review. See

Lapadat v. Bondi, 145 F.4th 942, 951 (9th Cir. 2025). We need not address that

1 Reyes-Robles’s husband and children are derivative beneficiaries of her asylum claim. All Petitioners filed their own applications for withholding of removal and CAT relief.

2 24-1378 question here because we would uphold the agency’s determination under either

standard.

Petitioners argue that the death of Reyes-Robles’s former husband, Nicolas,

should have been considered in assessing whether Reyes-Robles suffered past

persecution. “[H]arm to a petitioner’s close relatives, friends, or associates may

contribute to a successful showing of past persecution” where that harm is “part of

a pattern of persecution closely tied to [the petitioner her]self.” Wakkary v.

Holder, 558 F.3d 1049, 1060 (9th Cir. 2009) (cleaned up). Here, however, the IJ

found that the cause of Nicolas’s death was unknown. “[H]is killing may have

been a suicide or it may have been at the hands of evil men, but the information is

certainly unknown and there’s no basis to believe that those killers were somehow

targeting [Reyes-Robles] or her family.” Given the lack of evidence regarding the

circumstances of Nicolas’s death, the record does not compel a different

conclusion as to how he died. Additionally, Reyes-Robles did not receive the

threatening calls and messages until two years after Nicolas’s death and one year

after she had asked about reopening the investigation into his death. And the

record does not show that any caller tied a death threat to the warning not to reopen

Nicolas’s case. In these circumstances, Reyes-Robles has not shown that Nicolas’s

death was part of a pattern of persecution closely tied to her.

Petitioners further argue that the fact that men shot at their house after they

3 24-1378 left Mexico shows past persecution. The IJ found that there was insufficient

evidence to show that the shooters were targeting Reyes-Robles or her family,

considering that by the time of the shooting, Petitioners had long vacated the house

and had sold the house to their neighbor. Substantial evidence supports the IJ’s

finding.

Petitioners have not shown that the threatening phone calls Reyes-Robles

received amount to past persecution. Although “credible death threats alone can

constitute persecution, they constitute persecution in only a small category of

cases, and only when the threats are so menacing as to cause significant actual

suffering or harm.” Duran-Rodriguez v. Barr, 918 F.3d 1025, 1028 (9th Cir. 2019)

(cleaned up). “We generally look at all of the surrounding circumstances to

determine whether the threats are actually credible and rise to the level of

persecution. We have been most likely to find persecution where threats are

repeated, specific and combined with confrontation or other mistreatment. On the

other hand, cases with threats alone, particularly anonymous or vague ones, rarely

constitute persecution.” Id. (cleaned up).

The record here does not show that the death threats were credible or

particularly menacing. The callers were anonymous. Reyes-Robles stated in her

declaration that, at the time she received the threatening phone calls, people from

the cartel were “taking over the town” and “extorting people for any reason.” But

4 24-1378 there is no evidence that the cartel followed up on threats against anyone else they

were extorting in the town. The callers did not confront Reyes-Robles or her

family in person or physically harm them, even after she stopped answering the

calls. Thus, under either de novo or substantial evidence review, we conclude that

Reyes-Robles has not shown that she experienced past persecution.

2. Where there is no past persecution, a petitioner may still establish

eligibility for asylum based on a well-founded fear of future persecution. Hussain

v. Rosen, 985 F.3d 634, 645–46 (9th Cir. 2021). But in such cases, the petitioner

bears the burden to show that she cannot reasonably relocate to avoid future

persecution. See 8 C.F.R. § 1208.13(b)(2)–(3). The IJ found that Reyes-Robles

and her family did not meet that burden. Petitioners do not argue that the IJ erred

in so concluding. Rather, they argue only that because the IJ erroneously

determined that there was no past persecution, the IJ erred by failing to shift the

burden to the government to show that Reyes-Robles could reasonably relocate to

avoid future persecution. Because we uphold the IJ’s determination on past

persecution, the IJ did not err in placing the burden on Reyes-Robles to show that

she could not reasonably relocate to avoid future persecution.

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Related

Wakkary v. Holder
558 F.3d 1049 (Ninth Circuit, 2009)
Sinha v. Holder
564 F.3d 1015 (Ninth Circuit, 2009)
Jose Duran-Rodriguez v. William Barr
918 F.3d 1025 (Ninth Circuit, 2019)
Jose Guerra v. William Barr
974 F.3d 909 (Ninth Circuit, 2020)
Bilal Hussain v. Jeffrey Rosen
985 F.3d 634 (Ninth Circuit, 2021)
Karlena Dawson v. Merrick Garland
998 F.3d 876 (Ninth Circuit, 2021)
Singh v. Garland
97 F.4th 597 (Ninth Circuit, 2024)

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