Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT BERLYN MAYRENIS ESPINOZA- REYES v. TODD W. BLANCHE, Acting U.S Attorney General ) ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-16

The Sixth Circuit denied Berlyn Mayrenis Espinoza-Reyes’s petition for review of the Board of Immigration Appeals’ (BIA) decision denying her applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court held that the BIA correctly determined the petitioner failed to establish eligibility for relief. Regarding the asylum claims, the court applied the standard that a particular social group must be defined with particularity and social distinction, and cannot be circularly defined by the harm suffered. Relying on *Matter of S-S-F-M-*, 29 I. & N. Dec. 207 (A.G. 2025), which reinstated *Matter of A-B-I*, the court affirmed that Espinoza-Reyes’s proposed gender-based groups (“Guatemalan women unable to leave domestic relationships” and “Guatemalan women treated as property”) were impermissibly defined by the harm suffered and thus not cognizable. The court distinguished her case from *Juan Antonio v. Barr* because she lacked a specific race-based distinction and was not married to her abusive ex-partner. Furthermore, regarding family- and politics-based claims, the court applied the substantial-evidence standard and found no nexus between the threats she received and a protected ground. The threatening text messages were deemed vague and speculative, containing slurs like “old bitch” rather than references to political opinion or family ties, requiring an unsupported inferential leap to connect them to her asylum grounds. On the due process claim, the court ruled that the BIA was not required to address every argument or piece of evidence when its decision rested on a fatal flaw in the petitioner’s case (the lack of a cognizable social group). The court found no actual prejudice because the petitioner failed to identify specific evidence the agency ignored. Finally, the court declined to review the withholding of removal and CAT claims, holding that Espinoza-Reyes forfeited these arguments by failing to meaningfully challenge the BIA’s waiver finding in her opening brief. As a practical consequence, the petition for review is denied, leaving the BIA’s order affirming the Immigration Judge’s denial of all relief in place.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.