Velecela Rojas v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedSeptember 30, 2025
Docket23-7187
StatusUnpublished

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

Opinion

23-7187 Velecela Rojas v. Bondi BIA Reid, IJ A220 997 162/163

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 30th day of September, two thousand twenty-five.

PRESENT: JON O. NEWMAN, DENNY CHIN, MICHAEL H. PARK, Circuit Judges. _____________________________________

VERONICA PATRICIA VELECELA ROJAS, ALISSON MARIA ZAMBRANO VELECELA, Petitioners,

v. 23-7187 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________ FOR PETITIONERS: Paul B. Grotas, The Grotas Firm, P.C., New York, NY.

FOR RESPONDENT: Brian M. Boynton, Principal Deputy Assistant Attorney General, Civil Division; Sabatino F. Leo, Assistant Director, Katie E. Rourke, Trial Attorney, Office of Immigration Litigation, Civil Division, United States 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.

Petitioners Veronica Patricia Velecela Rojas and her minor child, natives and

citizens of Ecuador, seek review of an August 28, 2023, decision of the BIA

affirming a February 28, 2022, decision of an Immigration Judge (“IJ”) denying her

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

Against Torture (“CAT”). In re Veronica Patricia Velecela Rojas et al., Nos. A 220 997

162/163 (B.I.A. Aug. 28 2023), aff’g Nos. A 220 997 162/163 (Immigr. Ct. N.Y. City

Feb. 28, 2022). We assume the parties’ familiarity with the underlying facts and

procedural history.

We have reviewed the IJ’s decision as supplemented by the BIA. See Chen

v. Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). We review factual findings for

substantial evidence and questions of law and application of law to fact de novo. 2 Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018). “[T]he administrative

findings of fact are conclusive unless any reasonable adjudicator would be

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

I. Asylum and Withholding of Removal

Velecela Rojas fears returning to Ecuador because she was assaulted and

threatened after she reported drug smuggling activity by a cartel. “The burden of

proof is on the applicant to 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, 113–14 (2d Cir. 2022) (holding that the “one

central reason” standard applies to both asylum and withholding of removal).

First, we agree with the agency that Velecela Rojas’s proposed particular

social group of “individuals who report drug activities to the police” is not

cognizable. To state a social group claim, an applicant has to establish a cognizable

group, that is, a group “(1) composed of members who share a common immutable

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

society in question.” Paloka v. Holder, 762 F.3d 191, 196 (2d Cir. 2014) (quotation

marks omitted). “As to the particularity requirement, . . . the social group in

question must be defined by characteristics that provide a clear benchmark for 3 determining who falls within the group,” and “[t]he group must . . . be discrete

and have definable boundaries—it must not be amorphous, overbroad, diffuse, or

subjective.” Id. (quotation marks omitted). Social distinction focuses on “whether

society as a whole views a group as socially distinct.” Id. It requires more than a

“persecutor’s perception,” and “[p]ersecutory conduct aimed at a social group

cannot alone define the group.” Id. (quotation marks omitted). “When the harm

visited upon members of a group is attributable to the incentives presented to

ordinary criminals rather than to persecution, the scales are tipped away from

considering those people a particular social group.” Ucelo-Gomez v. Mukasey, 509

F.3d 70, 73 (2d Cir. 2007) (quotation marks omitted).

Velecela Rojas’s social group claim fails because nothing in the record

supports a conclusion that “individuals who report drug activities to the police”

is a particular social group—that is, there is no evidence that the group is distinct,

and is perceived as distinct in Ecuadorian society, from anyone else who may

interfere with the cartel’s business. Contrary to her arguments here, the agency

did not require testimony in open court as a prerequisite to finding a cognizable

group, and the lack of public cooperation with the police was an appropriate

consideration as the nature of the cooperation goes both to how discretely a group

is defined and to how society perceives a group. See Matter of H-L-S-A-, 28 I. & N. 4 Dec. 228, 237–39 (B.I.A. 2021). Velecela Rojas’s proposed group is distinguishable

from the cognizable group in Gashi v. Holder, 702 F.3d 130 (2d Cir. 2012), because

that group was limited to witnesses to a specific set of war crimes whose names

had been published. Id. at 136-37.

Nor does the record demonstrate that the cartel or its members targeted

Velecela Rojas because of an anti-drug, anti-cartel, or anti-gang political opinion.

To succeed on a political opinion claim, “[t]he applicant must . . . show, through

direct or circumstantial evidence, that the persecutor’s motive to persecute arises

from the applicant’s political belief.” Zhang v. Gonzales, 426 F.3d 540, 545 (2d Cir.

2005); see also Paloka, 762 F.3d at 196–97 (“Whether the requisite nexus exists

depends on the views and motives of the persecutor.” (quotation marks omitted)).

Such a political opinion “must involve some support for or disagreement with the

belief system, policies, or practices of a government and its instrumentalities, an

entity that seeks to directly influence laws, regulations, or policy, an organization

that aims to overthrow the government, or a group that plays some other similar

role in society.” Zelaya-Moreno v.

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Related

Jian Qiu Liu v. Holder
632 F.3d 820 (Second Circuit, 2011)
Yan Chen v. Alberto Gonzales, Attorney General, 1
417 F.3d 268 (Second Circuit, 2005)
Gashi v. Holder
702 F.3d 130 (Second Circuit, 2012)
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)
Zelaya-Moreno v. Wilkinson
989 F.3d 190 (Second Circuit, 2021)
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)
Garcia-Aranda v. Garland
53 F.4th 752 (Second Circuit, 2022)

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