9th Cir.

Ramirez Farfan v. Blanche

May 7, 2026 ·21-839 ·Unpublished · By Raj Patel

The United States Court of Appeals for the Ninth Circuit denied a petition for review of a Board of Immigration Appeals order. The court found substantial evidence supported the agency's denial of the petitioner's applications for cancellation of removal and other relief.

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Background

Jorge Ramirez Farfan, a native and citizen of Mexico, petitioned for review of a Board of Immigration Appeals order dismissing his appeal from an immigration judge’s decision. The immigration judge had denied his applications for cancellation of removal, asylum, withholding of removal, and protection under the Convention Against Torture.

The court’s reasoning

The court reviewed the case for substantial evidence regarding the exceptional and extremely unusual hardship standard. It found that the agency’s determination that Ramirez Farfan did not show such hardship was supported by substantial evidence. The court also noted that the petitioner waived review of the asylum and Convention Against Torture denials. Regarding due process, the court found no error because the petitioner failed to demonstrate both a violation of rights and prejudice. The court also found no error in the waiver determination regarding the particular social group challenge for withholding of removal.

What it means going forward

The denial of the petition leaves in place the Board of Immigration Appeals’ order denying the petitioner’s applications for relief from removal.

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