Case Explained: REYES-TORRES V. BLANCHE

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-07

The Ninth Circuit denied Jose Ramon Reyes-Torres’ petition for review of a Board of Immigration Appeals (BIA) order dismissing his appeal from an Immigration Judge’s denial of asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court held that Reyes-Torres failed to exhaust administrative remedies regarding his challenges to the nexus between the alleged persecution and protected grounds, the government control analysis, and the denial of CAT relief, as these specific issues were not raised in his appeal to the BIA. Even assuming these arguments were not waived, the court found substantial evidence supported the agency’s determination that gang members sought to recruit Reyes-Torres rather than persecute him based on a protected ground, thereby negating the required nexus for asylum and withholding of removal. Additionally, the court declined to address Reyes-Torres’ claim of ineffective assistance of counsel because he had filed a pending motion to reopen with the BIA on that basis, meaning the administrative remedy was not yet exhausted. Consequently, the petition is denied, the temporary administrative stay is lifted, and the motion to stay removal is dismissed.

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