Cristhofer Corrales-Herrera v. Merrick B. Garland, 21-3332

Petitioner Cristhofer Corrales-Herrera, a native of Honduras, entered the U.S. as an unaccompanied minor in 2014 and lived with his parents in Tennessee.
He applied (Jan 2016) for asylum, withholding of removal, and CAT protection, alleging gang recruitment, beatings, threats, robbery, and violence against family members in Honduras.
The Immigration Judge found him credible despite some inconsistencies but denied relief in Oct 2018; the BIA adopted the IJ’s reasoning and dismissed his appeal in Mar 2021.
Corrales-Herrera claimed membership in particular social groups: (1) Honduran males aged 14–18 lacking parental protection, and (2) family members of his father; the agency held the first group was not cognizable and the second cognizable but lacking nexus to persecution.
He argued on appeal that withholding should follow Guzman-Vazquez’s lower "a reason" standard, but did not present that argument to the BIA (failure to exhaust); his CAT claim failed for lack of evidence the Honduran government would acquiesce to torture.
The Sixth Circuit applied the substantial-evidence standard and denied the petition for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Asylum — eligibility via a "particular social group" and nexus to persecution	Corrales-Herrera: targeted because he is a young Honduran male without parental protection (and alternatively, a family member of his father)	Government: first group is not particular or socially distinct; no evidence of targeting on account of the accepted group	Court: agency reasonably found the teenage/no-parent group not cognizable; accepted family-member group but substantial evidence shows no persecution on that account — asylum denied
Withholding of removal — proper legal standard ("central reason" vs "a reason")	Corrales-Herrera: Guzman-Vazquez requires only that a protected ground be "a reason" for persecution	Government: BIA applied existing standard and petitioner failed to raise Guzman-Vazquez to the BIA	Held: Claim not considered because petitioner failed to exhaust the Guzman-Vazquez argument before the BIA; court lacks jurisdiction to entertain it
CAT protection — likelihood of torture and government acquiescence	Corrales-Herrera: gang violence he fears amounts to torture risk if returned	Government: no evidence the Honduran government would torture or acquiesce to private-actor torture	Court: Substantial evidence supports denial — petitioner failed to show torture by or with government acquiescence

Marikasi v. Lynch, 840 F.3d 281 (6th Cir. 2016) (standard for reviewing BIA final orders)
Khalili v. Holder, 557 F.3d 429 (6th Cir. 2009) (deference to BIA when it issues a separate opinion; exhaustion jurisdictional rule)
Umana-Ramos v. Holder, 724 F.3d 667 (6th Cir. 2013) (general gang violence insufficient absent targeting on protected ground)
Bonilla-Morales v. Holder, 607 F.3d 1132 (6th Cir. 2010) (requirements for a cognizable particular social group)
Bi Xia Qu v. Holder, 618 F.3d 602 (6th Cir. 2010) (immutability and centrality requirements for social groups)
Guzman-Vazquez v. Barr, 959 F.3d 253 (6th Cir. 2020) (withholding standard: protected ground need only be "a reason")
Ramani v. Ashcroft, 378 F.3d 554 (6th Cir. 2004) (exhaustion requirement before the BIA)
Patel v. Gonzales, [citation="126 F. App'x 283"] (6th Cir. 2005) (generalized criminality or lawlessness typically not persecution)
Mapouya v. Gonzales, 487 F.3d 396 (6th Cir. 2007) (CAT requires government infliction or acquiescence)
Menijar v. Lynch, 812 F.3d 491 (6th Cir. 2015) (CAT does not protect against torture solely by private actors)