GERSON EDUARDO ALFARO MANZANO v. MERRICK B. GARLAND, Attorney General Nos. 22-704 22-1521
The Ninth Circuit held that an asylum seeker's Jehovah's Witness faith was one central reason for his persecution by Salvadoran gangs, even though the gangs also sought to extort money from him. The court clarified that a protected ground need not be the sole motive to qualify for asylum if it would independently cause the harm.