Case Explained: QUINONEZ-ROS V. BLANCHE

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-09

The ninth-circuit denied the petition in part and vacated and remanded it in part regarding Aniceto Quinonez-Ros’s request for withholding of removal, Convention Against Torture (CAT) protection, and cancellation of removal. The court held that substantial evidence supported the Board of Immigration Appeals’ (BIA) denial of withholding of removal because the petitioner failed to establish a nexus between his proposed particular social groups and the threats he faced from an individual in Guatemala. Similarly, the court found substantial evidence supported the denial of CAT relief, as the record did not compel the conclusion that the Guatemalan government would acquiesce to his torture or that he could not relocate within the country. The court also affirmed that the BIA did not abuse its discretion in denying motions to reopen based on ineffective assistance of counsel and to withdraw pleadings, finding the petitioner failed to demonstrate “egregious” circumstances or fundamental unfairness under applicable standards. However, the court vacated and remanded the case specifically regarding eligibility for cancellation of removal. The court determined that a prior remand order may have been unclear as to whether the petitioner could submit additional evidence to prove that his removal would cause “exceptional and extremely unusual” hardship to his U.S.-citizen daughter. Consequently, the matter is remanded to the BIA to allow Quinonez-Ros the opportunity to further develop the record on this specific issue.

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