Caz v. Garland, 84 F.4th 22

Petitioner Tomas Caz, an Ecuadorian of Quechua heritage, was attacked twice in Guayaquil (2012–2013), including threats with a firearm and machete; he returned to Riobamba to recover and lived there without further violence for about a year.
Caz fled to the United States in 2014, expressed fear of return, and passed a credible-fear screening; removal proceedings followed.
At the immigration hearing, the IJ found Caz not credible (noting inconsistencies) but alternatively denied asylum on the merits, concluding the attacks did not amount to persecution or lacked a nexus to ethnicity and that internal relocation to Riobamba was reasonable; withholding and CAT relief were also denied.
The BIA affirmed, assuming Caz credible, but agreeing that he failed to show nexus and that internal relocation was feasible; it deemed the CAT claim waived.
On petition for review, the First Circuit applied the substantial-evidence standard and denied the petition, resolving the case on the internal-relocation issue (finding substantial evidence supported the BIA/IJ conclusion that Caz could reasonably relocate to Riobamba).

Issue	Caz's Argument	Government/BIA Argument	Held
1. Adverse credibility finding	BIA/IJ erred in adverse-credibility determination; totality of circumstances favored Caz	IJ’s credibility findings were supported by perceived inconsistencies; BIA avoided deciding credibility by assuming credibility	Not reached as dispositive; BIA assumed credibility for decision and court reviewed merits under that assumption
2. Past persecution / nexus to Quechua status	Attacks were motivated by Quechua heritage and constituted past persecution	Attacks did not establish motive tied to protected ground or rise to persecution	Not necessary to decide—court assumed in Caz’s favor for purposes of relocation analysis
3. Internal relocation feasibility	Relocating within Ecuador (Riobamba) would be unsafe or unreasonable given discrimination and country conditions	Caz previously lived safely in Riobamba, his parents remain there unharmed, and he conceded other areas might be safe	Held for Government: substantial evidence supports the IJ/BIA that internal relocation to Riobamba was reasonable; asylum and withholding denied

Aguilar-Escoto v. Garland, 59 F.4th 510 (definition of persecution by private actors when government unwilling/unable to control)
Rosales-Justo v. Sessions, 895 F.3d 154 (private-actor persecution framework)
Khattak v. Holder, 704 F.3d 197 (internal relocation doctrine and reasonableness inquiry)
Tendean v. Gonzales, 503 F.3d 8 (relief standards; higher showing for withholding)
López-Pérez v. Garland, 26 F.4th 104 (relevance of prior internal relocation and family’s continued safety)
Chen Qin v. Lynch, 833 F.3d 40 (family members’ continued residence relevant to relocation analysis)
Odei v. Garland, 71 F.4th 75 (substantial-evidence standard in immigration review)
Albathani v. INS, 318 F.3d 365 (reversal under substantial-evidence review requires compelling contrary evidence)
Rashad v. Mukasey, 554 F.3d 1 (articulation of substantial-evidence review standard)