Background
Cindy Sarai Villatoro-Ramos, a native and citizen of El Salvador, sought review of a Board of Immigration Appeals decision affirming an Immigration Judge’s denial of her application for asylum, withholding of removal, and Convention Against Torture relief. She also raised a fear of unrelated violence by Guatemalan criminals.
The court’s reasoning
The panel unanimously concluded that the petitioner forfeited any challenge to the agency’s denial of asylum and withholding of removal by failing to meaningfully develop arguments to rebut the agency’s conclusions. Her opening brief merely asserted in a conclusory fashion that her proposed particularized social groups were cognizable without supporting analysis. Additionally, the court noted that her fear of unrelated violence by Guatemalan criminals was not raised below and would not be considered. Finally, the court deemed her request for Convention Against Torture relief forfeited because she raised no arguments to rebut the agency’s denial in her brief.
What it means going forward
The denial of the petition leaves in place the Board of Immigration Appeals’ decision denying relief. The petitioner’s motion to stay removal pending appeal was also denied.
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