Rojas-Toledo v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedNovember 13, 2025
Docket24-500
StatusUnpublished

This text of Rojas-Toledo v. Bondi (Rojas-Toledo 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
Rojas-Toledo v. Bondi, (2d Cir. 2025).

Opinion

24-500 Rojas-Toledo v. Bondi BIA Hom, IJ A209 980 447

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.

1 At a stated term of the United States Court of Appeals for the Second 2 Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley 3 Square, in the City of New York, on the 13th day of November, two thousand 4 twenty-five. 5 6 PRESENT: 7 DENNIS JACOBS, 8 PIERRE N. LEVAL, 9 RAYMOND J. LOHIER, JR., 10 Circuit Judges. 11 _____________________________________ 12 13 ANGELICA MARIBEL ROJAS-TOLEDO, 14 15 Petitioner, 16 17 v. 24-500 18 NAC 19 PAMELA BONDI, UNITED STATES 20 ATTORNEY GENERAL, 21 Respondent. 22 _____________________________________ 23 24 FOR PETITIONER: Reuben S. Kerben, Esq., Kerben Law Firm, 1 P.C., Kew Gardens, NY. 2 3 FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant 4 Attorney General; Song Park, Assistant 5 Director; Alanna T. Duong, Trial Attorney, 6 Office of Immigration Litigation, United 7 States Department of Justice, Washington, 8 DC.

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

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

11 DECREED that the petition for review is DENIED.

12 Petitioner Angelica Maribel Rojas-Toledo, a native and citizen of Ecuador,

13 seeks review of a January 30, 2024, decision of the BIA affirming a February 12,

14 2019, decision of an Immigration Judge (“IJ”) denying her application for asylum

15 and withholding of removal. 1 In re Angelica Maribel Rojas-Toledo, No. A 209 980 447

16 (B.I.A. Jan. 30, 2024), aff’g No. A 209 980 447 (Immig. Ct. N.Y. City Feb. 12, 2019).

17 We assume the parties’ familiarity with the underlying facts and procedural

18 history.

19 We have reviewed the IJ’s decision as modified and supplemented by the

1We do not address petitioner’s claim under the Convention Against Torture because she does not address it in her brief. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (“We consider abandoned any claims not adequately presented in the appellant’s brief, and an appellant’s failure to make legal or factual arguments constitutes abandonment” (quotation marks omitted)). 2 1 BIA. See Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005); Yan

2 Chen v. Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). We review fact-finding “under

3 the substantial evidence standard” and questions of law and the application of law

4 to fact de novo. Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018). “[T]he

5 administrative findings of fact are conclusive unless any reasonable adjudicator

6 would be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B).

7 An applicant for asylum and withholding of removal has the burden to

8 establish past persecution or a fear of future persecution and that “race, religion,

9 nationality, membership in a particular social group, or political opinion was or

10 will be at least one central reason for persecuting [her].” Id. § 1158(b)(1)(B)(i); see

11 also id. § 1231(b)(3)(A); 8 C.F.R. §§ 1208.13(b), 1208.16(b); Quituizaca v. Garland, 52

12 F.4th 103, 109–14 (2d Cir. 2022) (“one central reason” standard applies to both

13 asylum and withholding of removal). An applicant must prove “a sufficiently

14 strong nexus” between the persecution and a protected ground. Castro v. Holder,

15 597 F.3d 93, 100 (2d Cir. 2010). And where, as here, an applicant seeks relief based

16 on membership in a particular social group, she must show both that the group is

17 cognizable and that she was harmed on account of her membership in that group.

18 Paloka v. Holder, 762 F.3d 191, 195 (2d Cir. 2014).

3 1 A group is cognizable if it is “(1) composed of members who share a

2 common immutable characteristic, (2) defined with particularity, and (3) socially

3 distinct within the society in question.” Id. at 196 (quoting Matter of M-E-V-G-, 26

4 I. & N. Dec. 227, 237 (B.I.A. 2014)); see also Matter of W-G-R-, 26 I. & N. Dec. 208,

5 212–18 (B.I.A. 2014); Ucelo-Gomez v. Mukasey, 509 F.3d 70, 72–74 (2d Cir. 2007). We

6 agree with the agency’s determination that Rojas-Toledo’s particular social

7 group—“victims of domestic violence who were unsuccessful in seeking police

8 assistance”—is not cognizable because it is impermissibly circular and defined

9 only by the claimed persecution. “Persecutory conduct aimed at a social group

10 cannot alone define the group, which must exist independently of the

11 persecution.” Paloka, 762 F.3d at 196 (quotation marks omitted); Matter of M-E-V-

12 G-, 26 I. & N. Dec. at 232 (reiterating that “a ‘particular social group’ cannot be

13 defined exclusively by the claimed persecution, . . . it must be ‘recognizable’ as a

14 discrete group by others in the society, and . . . it must have . . . well-defined

15 boundaries,” i.e., the group “must not be amorphous, overbroad, diffuse, or

16 subjective”).

17 Rojas-Toledo challenges the authority the agency relied on to find her

18 particular social group not cognizable, but we discern no error. The IJ’s 2019

4 1 decision cited Matter of A-B-, 27 I. & N. Dec. 316, 335 (A.G. 2018) (“Matter of A-B-

2 I”), which held that victims of domestic violence generally are not a cognizable

3 social group because the group is defined by its harm. As Rojas-Toledo points out,

4 that decision was vacated by the Attorney General in 2021 in Matter of A-B-III, 28

5 I. & N. Dec. 307, 309 (A.G. 2021). However, A-B-I was good law at the time of the

6 IJ’s 2019 decision, and the BIA’s 2024 decision acknowledged the vacatur, but

7 agreed with the IJ’s cognizability determination because the proposition for which

8 the IJ cited A-B-I—that a particular social group must exist independently of the

9 harm asserted—was an accurate statement of the law. See Paloka, 762 F.3d at 196;

10 Matter of M-E-V-G-, 26 I. & N. Dec. at 232, 239.

11 We also reject Rojas-Toledo’s argument that her group is cognizable under

12 Matter of A-R-C-G-, 26 I. & N. Dec. 388 (B.I.A. 2014), which the BIA instructed IJs

13 to follow in A-B-III. See Matter of A-B-III, 28 I. & N. Dec. at 307–08. 2 In A-R-C-G-,

14 the BIA determined that “married women in Guatemala who are unable to leave

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Related

Castro v. Holder
597 F.3d 93 (Second Circuit, 2010)
Yan Chen v. Alberto Gonzales, Attorney General, 1
417 F.3d 268 (Second Circuit, 2005)
Ucelo-Gomez v. Mukasey
509 F.3d 70 (Second Circuit, 2007)
Silvana Paloka v. Eric H. Holder, Jr.
762 F.3d 191 (Second Circuit, 2014)
A-B
27 I. & N. Dec. 316 (Board of Immigration Appeals, 2018)
W-G-R
26 I. & N. Dec. 208 (Board of Immigration Appeals, 2014)
A-R-C-G
26 I. & N. Dec. 388 (Board of Immigration Appeals, 2014)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Santos-Zacaria v. Garland
598 U.S. 411 (Supreme Court, 2023)
Ud Din v. Garland
72 F.4th 411 (Second Circuit, 2023)
s-S-F-M
29 I. & N. Dec. 207 (Board of Immigration Appeals, 2025)

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