Alma Delia Reyes Galeana v. Merrick B. Garland, 94 F.4th 555

Alma Reyes Galeana, a Mexican citizen and former restaurant owner from Guerrero, Mexico, fled to the United States after repeated threats and attempted extortion by local gangs.
She sought asylum and withholding of removal for herself and her three daughters, asserting she belonged to a “particular social group” consisting of Mexican business owners.
Both the Immigration Judge (IJ) and Board of Immigration Appeals (BIA) rejected her claim, finding Mexican business owners were not a recognized particular social group for immigration relief.
Reyes Galeana petitioned the Sixth Circuit for review, challenging the BIA’s legal conclusion.
The court’s review focused on whether membership in the proposed social group satisfied established legal criteria.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mexican business owners constitute a “particular social group” for asylum and withholding of removal.	Mexican business owners share characteristics that should qualify as a particular social group given the targeted violence they face.	The group is too broad, lacks particularity, and is not socially distinct in Mexican society; not all business owners are equally targeted or identifiable as a class.	No, the court held Mexican business owners are not a particular social group under asylum law.

Gonzalez-De Leon v. Barr, 932 F.3d 489 (6th Cir. 2019) (sets out the three requirements for a cognizable particular social group: immutability, particularity, and social distinction)
Cruz-Guzman v. Barr, 920 F.3d 1033 (6th Cir. 2019) (discusses the need for discrete and definable boundaries in particularity analysis)
Kante v. Holder, 634 F.3d 321 (6th Cir. 2011) (explains that a group defined by risk of persecution alone lacks the necessary particularity and social distinction)
Zaldana Menijar v. Lynch, 812 F.3d 491 (6th Cir. 2015) (clarifies that social distinction requires recognition by society at large, not just by persecutors)