Case Explained: RODAS-FLORES, ET AL. V. BLANCHE

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-24

The ninth-circuit denied the petition for review of the Board of Immigration Appeals’ order dismissing the petitioners’ appeals from an immigration judge’s decision denying their applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court held that substantial evidence supported the agency’s determination that the petitioners failed to demonstrate persecution on account of a protected ground, noting that purely personal retribution or harassment motivated by random violence bears no nexus to a protected ground. Consequently, the petitioners also failed to satisfy the standard for withholding of removal. Regarding the CAT claim, the court found no error in the BIA’s conclusion that Rodas-Flores waived review of the immigration judge’s denial because she did not raise the merits of the claim before the agency, thereby failing to exhaust administrative remedies under 8 U.S.C. § 1252(d)(1). The motion to stay removal was denied as moot. As a result, the petitioners’ claims for asylum and withholding of removal are rejected, and their request for CAT protection is dismissed due to waiver.

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