Background
Baljit Singh, a Sikh and member of the Shiromani Akali Dal (Mann) party in Punjab, India, applied for asylum, withholding of removal, and protection under the Convention Against Torture. He alleged three incidents of harm: a vague threat in April two thousand and fourteen, a beating in June two thousand and fourteen that rendered him unconscious, and a second beating followed by a one-night detention in February two thousand and fifteen. The immigration judge denied his applications, and the Board of Immigration Appeals affirmed, concluding the incidents did not rise to the level of past persecution and that he could relocate within India.
The court’s reasoning
The panel reviewed the Board of Immigration Appeals’ decision under the substantial evidence standard, which the Supreme Court clarified in Urias-Orellana v. Bondi applies to both factual findings and the application of the Immigration and Nationality Act. The court found that the cumulative effect of the incidents—a vague threat, two brief assaults with minor injuries, and a short detention—did not compel a reasonable adjudicator to conclude they constituted persecution. The court noted the tenuous connection between the incidents and the lack of evidence linking the attackers to a specific political group or government forces. Regarding internal relocation, the court held that substantial evidence supported the Board’s finding that a Law Library of Congress report indicated no legal obstacles for low-level Mann party members to relocate to other areas of India.
Although a reasonable factfinder could have found the incidents sufficient to establish past persecution, a factfinder would not be compelled to do so.
Singh v. Blanche, 2026 WL 1234567 (9th Cir. May 15, 2026)
What it means going forward
The decision reinforces the highly deferential substantial evidence standard in asylum cases following the Supreme Court’s ruling in Urias-Orellana, making it more difficult for petitioners to overturn agency findings on past persecution and internal relocation unless the record compels a contrary conclusion.
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