Ivonne Ramirez Sanchez v. Jefferson Sessions, 706 F. App'x 897

Ivonne Otilia Ramirez Sanchez, a Peruvian national, petitions for review of the BIA’s denial of withholding of removal.
Ramirez claimed membership in a proposed particular social group: family members who were all victims of criminals.
Her family members were attacked, kidnapped, and threatened by criminals seeking information tied to her husband’s employment at a prestigious hotel.
Ramirez testified the assaults, kidnappings, and threatening calls were motivated by the criminals’ desire to obtain information to rob the hotel.
The BIA found Ramirez failed to show the harm was "because of" membership in the proposed social group (no nexus to protected ground).
The Ninth Circuit denied review, holding substantial evidence supports the BIA’s nexus finding and the outcome would be the same under either the "a reason" (withholding) or "one central reason" (asylum) standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Nexus to a protected ground for withholding of removal	Ramirez: family members were targeted as a social group and persecuted for that membership	BIA/Respondent: attacks motivated by criminals' intent to extort/rob the hotel, not family membership	Court: Denied; substantial evidence supports no nexus to a protected ground
Applicable causal standard for withholding	Ramirez: withholding requires only that the protected ground be "a reason" for persecution	BIA applied "one central reason" but outcome unchanged; court notes correct standard is "a reason"	Court: Even under either standard, Ramirez failed to show persecution because of a protected ground

Al-Harbi v. INS, 242 F.3d 882 (9th Cir. 2001) (explains nexus requirement for withholding of removal)
Barajas-Romero v. Lynch, 846 F.3d 351 (9th Cir. 2017) (clarifies "a reason" standard for withholding vs. "one central reason" for asylum)
Zetino v. Holder, 622 F.3d 1007 (9th Cir. 2010) (criminally motivated theft or random violence lacks nexus to a protected ground)