Zapet-Alvarado v. Bondi

CourtCourt of Appeals for the First Circuit
DecidedSeptember 22, 2025
Docket24-1782
StatusPublished

This text of Zapet-Alvarado v. Bondi (Zapet-Alvarado 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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Zapet-Alvarado v. Bondi, (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1782

WUENDY ZAPET-ALVARADO; G.J.A.Z.,

Petitioners,

v.

PAMELA J. BONDI, Attorney General,

Respondent.

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

Before

Montecalvo, Aframe, Circuit Judges, and Vélez-Rivé,* U.S. District Judge.

Kristian Robson Meyer, with whom Kevin P. MacMurray and MacMurray & Associates were on brief, for petitioners.

Jesse D. Lorenz, Trial Attorney, Office of Immigration Litigation, with whom Brett A. Shumate, Acting Assistant Attorney General, Civil Division, and Brett F. Kinney, Senior Litigation Counsel, were on brief, for respondent.

September 22, 2025

* Of the District of Puerto Rico, sitting by designation. AFRAME, Circuit Judge. Wuendy Celeny Zapet-Alvarado

("Zapet"), a citizen of Guatemala, petitions for review of the

administrative denial of her applications for asylum, withholding

of removal under the Immigration and Nationality Act ("INA"), and

protection under the Convention Against Torture ("CAT"). Zapet

argues that the Board of Immigration Appeals ("BIA") erred in

affirming the immigration judge's (the "IJ," and collectively with

the BIA "the agency") determinations that her asylum application

was untimely and that she did not qualify for withholding of

removal or CAT protection. We lack jurisdiction to review the

discretionary denial of Zapet's asylum application and determine

that substantial evidence supports the denial of her withholding

of removal and CAT claims.

I.

A. Zapet and her minor son arrived in the United States on

or about August 28, 2021, without visas or official immigration

status. On November 18, 2022, the Department of Homeland Security

served Zapet a notice to appear and initiated removal proceedings.

Nearly a year later, on October 19, 2023, Zapet applied for asylum,

withholding of removal, and CAT protection, with her son as a

2 derivative applicant.1 A few months later, the IJ convened a

removal hearing to consider Zapet's applications for relief.

The IJ made the following findings. Zapet is a native

and citizen of Guatemala. Her home village of Loma Linda is in an

area subject to land conflicts between the Tajumulco village and

the Ixtahuacan community. For roughly four years before Zapet

arrived in the United States, unidentified hooded men approached

Zapet and her husband to obtain their support in the ongoing

conflict.2 The men did not specify the nature of the support they

sought. However, the men threatened to kidnap Zapet's children if

support was not forthcoming. The threats continued until 2021,

when Zapet left for the United States. Zapet never called the

police or otherwise informed the authorities of the men's threats.

No kidnapping occurred and neither she, her husband, nor her

children suffered physical harm while in Guatemala.

1 Zapet's son also applied separately for the same relief on the same grounds asserted by Zapet. Because Zapet was the lead respondent before the agency and the only one who testified, we will focus our discussion on her. See Chun Méndez v. Garland, 96 F.4th 58, 61 n.1 (1st Cir. 2024). 2 At oral argument in this Court, Zapet's counsel disputed the period over which the threat occurred. Arguments first raised at oral argument are waived. See, e.g., Capen v. Campbell, 134 F.4th 660, 675 (1st Cir. 2025).

3 B.

Prior to the removal hearing, Zapet conceded

removability. The IJ accepted that stipulation and addressed

Zapet's asylum, withholding of removal, and CAT claims.

The IJ denied Zapet's asylum application as untimely.

While Zapet did not dispute that she filed her asylum claim after

the one-year deadline following her arrival in the United States,

8 U.S.C. § 1158(a)(2)(B), she claimed that she should nonetheless

receive relief from that deadline because of extraordinary

circumstances, id. § 1158(a)(2)(D). Zapet specifically cited her

unawareness of U.S. immigration laws as the extraordinary

circumstance. The IJ rejected this argument, concluding that a

"lack of knowledge of [i]mmigration laws is not considered an

extraordinary circumstance."

The IJ turned next to whether Zapet had established past

persecution or a well—founded fear of future persecution as needed

to qualify for asylum. The IJ concluded that the hooded men's

threats to kidnap Zapet's children did not constitute past

persecution because the threats were not serious enough to meet

the applicable standard. In support of this conclusion, the IJ

observed that the threats were never fulfilled despite occurring

over a four-year period, that "the threats were not menacing in

nature," and that the threats did not cause Zapet or her family to

suffer physical harm.

4 The IJ also rejected Zapet's claims that she had a

well-founded fear of future persecution. Zapet had argued that

she feared future threats if she were to return to Guatemala based

on her indigenous race, political opinion, familial relationships,

and landowner status. The IJ noted that Zapet had not: (1) shown

a connection between the identified protected grounds and the

previous threats; (2) demonstrated how the conflict between the

Tajumulco village and the Ixtahuacan community had affected or

harmed her; or (3) established why harm should be expected on her

return to Guatemala, given that the threats about which she

complains went unfulfilled for four years. The IJ also stated

that, because Zapet had remained safely in Guatemala for four years

while the threats persisted, it was reasonable to believe that she

could relocate safely within the country. For these reasons, the

IJ concluded that Zapet's asylum claim failed even if timely. The

IJ likewise denied her withholding of removal claim, finding that

Zapet's failure to establish eligibility for asylum made her

necessarily unable to satisfy the "highe[r] burden" required to

prove withholding of removal.3

3 While qualifying for asylum requires that "an applicant must establish that she suffered in the past or has a well-founded fear of suffering in the future[,] . . . [t]o obtain withholding of removal, the burden is even higher: The applicant 'must establish a clear probability that, if returned to [her] homeland, [s]he will be persecuted on account of a statutorily protected ground.'" Varela-Chavarria v. Garland, 86 F.4th 443, 449 (1st

5 Finally, the IJ rejected Zapet's application for CAT

protection because Zapet failed to demonstrate that she would more

likely than not be tortured upon her return to Guatemala or that

the Guatemalan government would consent or acquiesce in any

torture. As support for this determination, the IJ again relied

on Zapet's failure to demonstrate that she suffered physical harm

in Guatemala and noted that the threats Zapet received did not

involve imminent death or harm to her.

Following the IJ's decision, Zapet appealed each adverse

ruling to the BIA. For her untimely asylum claim, Zapet asserted

additional reasons to justify extraordinary circumstances

warranting relief from the one-year deadline, including lack of

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