Reyes Santos v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedMay 6, 2025
Docket23-7182
StatusUnpublished

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

Bluebook
Reyes Santos v. Bondi, (2d Cir. 2025).

Opinion

23-7182 Reyes Santos v. Bondi BIA Christensen, IJ A208 868 157

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 6th day of May, two thousand twenty- five.

PRESENT: JOSÉ A. CABRANES, MICHAEL H. PARK, WILLIAM J. NARDINI, Circuit Judges. _____________________________________

JOSE LEONEL REYES SANTOS, Petitioner,

v. 23-7182 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Bruno J. Bembi, Hempstead, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Jessica E. Burns, Senior Litigation Counsel; Rosanne M. Perry, Trial Attorney, Office of Immigration Litigation, U.S. Department of Justice, Washington, DC.

UPON DUE CONSIDERATION of this petition for review of a Board of

Immigration Appeals (“BIA”) decision, it is hereby ORDERED, ADJUDGED,

AND DECREED that the petition for review is DENIED.

Petitioner Jose Leonel Reyes Santos, a native and citizen of El Salvador,

seeks review of a September 11, 2023 decision of the BIA summarily affirming an

October 21, 2019 decision of an Immigration Judge (“IJ”) denying his application

for asylum, withholding of removal, and relief under the Convention Against

Torture (“CAT”). In re Jose Leonel Reyes Santos, No. A208 868 157 (B.I.A. Sept. 11,

2023), aff’g No. A208 868 157 (Immig. Ct. N.Y.C. Oct. 21, 2019). We assume the

parties’ familiarity with the underlying facts and procedural history.

We have reviewed the IJ’s decision because the BIA summarily affirmed it

without opinion. See Li v. Mukasey, 529 F.3d 141, 146 (2d Cir. 2008). We review

fact-finding “under the substantial evidence standard” and questions of law and

the application of law to fact de novo. Gao v. Sessions, 891 F.3d 67, 76 (2d Cir.

2018). “[T]he administrative findings of fact are conclusive unless any reasonable

2 adjudicator would be compelled to conclude to the contrary.” 8 U.S.C.

§ 1252(b)(4)(B).

I. Notice to Appear

Reyes Santos argues that his Notice to Appear did not vest jurisdiction with

the immigration court because it lacked the date and time of his initial hearing.

This argument is not properly before us because he did not exhaust it before the

agency. See Punin v. Garland, 108 F.4th 114, 124 (2d Cir. 2024) (“[W]hen an

argument made to this Court cannot be closely matched up with a specific

argument made to the BIA, it has not been properly exhausted and we cannot hear

it.”). Even so, the argument lacks merit because the omission of a hearing date

from a Notice to Appear does not strip the immigration court of jurisdiction where,

as here, the petitioner was later sent a hearing notice with that information. See

Cupete v. Garland, 29 F.4th 53, 57 (2d Cir. 2022).

II. Asylum and Withholding of Removal

Reyes Santos asserted a fear of recruitment by gangs, alleging that gang

members had intimidated him and other family members in the past and had once

tried to break into his grandmother’s house. An applicant for asylum and

withholding of removal has the burden to establish past persecution or at least a

3 well-founded fear that he will be persecuted in the future, 8 C.F.R. §§ 1208.13(b),

1208.16(b), and “the applicant must establish that race, religion, nationality,

membership in a particular social group, or political opinion was or will be at least

one central reason for persecuting the applicant,” 8 U.S.C. § 1158(b)(1)(B)(i); see

Quituizaca v. Garland, 52 F.4th 103, 109–14 (2d Cir. 2022) (the “one central reason”

standard applies to both asylum and withholding of removal).

Reyes Santos has abandoned his asylum and withholding of removal claims

by failing to present sufficient factual or legal arguments regarding his alleged

protected grounds. “We consider abandoned any claims not adequately

presented in an appellant’s brief, and an appellant’s failure to make legal or factual

arguments constitutes abandonment.” Debique v. Garland, 58 F.4th 676, 684 (2d

Cir. 2023) (quotation marks omitted). Reyes Santos has abandoned political

opinion as a basis for asylum and withholding by failing to mention it in his brief.

See id. Moreover, “refusing to join a gang without more does not constitute a

political opinion.” Zelaya-Moreno v. Wilkinson, 989 F.3d 190, 200 (2d Cir. 2021)

(quotation marks omitted).

Reyes Santos’s challenges to the IJ’s particular social group findings are also

abandoned. He had the burden to establish both that his proposed group was

4 cognizable, and that his membership in the group was a reason gang members

targeted him or would target him. See Paloka v. Holder, 762 F.3d 191, 196–97 (2d

Cir. 2014). To constitute a cognizable particular social group, a group must be

“(1) composed of members who share a common immutable characteristic,

(2) defined with particularity, and (3) socially distinct within the society in

question.” Id. at 196 (quoting Matter of M-E-V-G-, 26 I. & N. Dec. 227, 237 (B.I.A.

2014)). The IJ determined that Reyes Santos’s proposed particular social group—

“Salvadoran youth who are deported back to El Salvador and left without familial

protection”—was not cognizable because there was no evidence that it was

socially distinct, because the term “familial protection” was vague, given that

Reyes Santos lived with his grandmother, who provided some familial protection,

and because the term “youth” was subjective.

Reyes Santos generally contends that he established a particular social

group, but he does not cite record evidence that Salvadoran society views the

group as distinct, and he does not address particularity other than to state that the

size of the group does not matter. He has thus abandoned these grounds for relief

by making only conclusory arguments that he established a cognizable social

group. See Debique, 58 F.4th at 684; Zhang v. Gonzales, 426 F.3d 540

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Related

Shunfu Li v. Mukasey
529 F.3d 141 (Second Circuit, 2008)
Ucelo-Gomez v. Mukasey
509 F.3d 70 (Second Circuit, 2007)
Savchuck v. Mukasey
518 F.3d 119 (Second Circuit, 2008)
Silvana Paloka v. Eric H. Holder, Jr.
762 F.3d 191 (Second Circuit, 2014)
Zelaya-Moreno v. Wilkinson
989 F.3d 190 (Second Circuit, 2021)
Quintanilla v. Garland
3 F.4th 569 (Second Circuit, 2021)
M-E-V-G
26 I. & N. Dec. 227 (Board of Immigration Appeals, 2014)
Cupete v. Garland
29 F.4th 53 (Second Circuit, 2022)
Quituizaca v. Garland
52 F.4th 103 (Second Circuit, 2022)
Mu Xiang Lin v. United States Department of Justice
432 F.3d 156 (Second Circuit, 2005)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Vera Punin v. Garland
108 F.4th 114 (Second Circuit, 2024)

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Reyes Santos v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reyes-santos-v-bondi-ca2-2025.