Emeterio Rodriguez-Cortez v. Merrick Garland, 19-73206

Petitioner Emeterio Rodriguez‑Cortez, a Mexican citizen, sought withholding of removal and CAT protection; the BIA affirmed the IJ's denial and this court reviews under the substantial‑evidence standard.
Petitioner contends the Knights Templar will persecute him because of his family ties.
Record evidence indicated the Knights Templar engage in extortion and profit‑motivated violence (e.g., demanding a community “quota”).
The BIA found no nexus between alleged harm and a protected ground and concluded the gang’s motivation was financial rather than targeted at petitioner’s family status.
For CAT, the BIA determined the threat was localized to petitioner’s hometown and that internal relocation within Mexico was reasonable, so petitioner failed to prove it was "more likely than not" he would be tortured or killed.
The Ninth Circuit denied the petition, holding the BIA’s conclusions are supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Withholding of removal (nexus)	Knights Templar will persecute Rodriguez‑Cortez because of his family ties	Gang targets are motivated by profit/extortion, not protected characteristics	Denied — no nexus; BIA decision supported by substantial evidence
CAT protection (likelihood; relocation)	More likely than not he will be tortured or killed if returned	Threat is localized and the petitioner could safely relocate within Mexico	Denied — petitioner failed to show likelihood of torture or inability to relocate

Zetino v. Holder, 622 F.3d 1007 (9th Cir. 2010) (gang harassment motivated by theft/random violence does not establish nexus to a protected ground)
Duran‑Rodriguez v. Barr, 918 F.3d 1025 (9th Cir. 2019) (review of BIA factual findings is for substantial evidence)
Maldonado v. Lynch, 786 F.3d 1155 (9th Cir. 2015) (agency must consider internal relocation when assessing CAT claims)