Leslyn Yadery Lazaro-Ruano v. U.S. Attorney General, 19-14276

Petitioner Leslyn Yadery Lazaro-Ruano, a Guatemalan national, applied for asylum, withholding of removal, and CAT protection after entering the U.S. unlawfully; she conceded removability.
In an amended application she alleged past sexual abuse by an uncle and by police, and later being forced into prostitution by police-run operators; she fled after threats and other attacks and listed her daughter as a derivative beneficiary.
The IJ denied relief on four alternative grounds: adverse credibility, lack of corroboration, untimeliness of the asylum application, and failure to identify a cognizable "particular social group" (PSG).
The BIA affirmed, holding the proposed PSG—"young Guatemalan women forced into prostitution"—was circularly defined (i.e., defined by the persecution itself) and therefore not cognizable; the BIA waived or declined to address the IJ’s other findings.
The Eleventh Circuit reviewed de novo the legal question whether the proposed PSG was cognizable and affirmed the BIA, denying the petition; jurisdictional and exhaustion limits precluded review of the IJ’s credibility, corroboration, timeliness, and some unexhausted claims.

Issue	Lazaro-Ruano's Argument	Government's Argument	Held
Whether the proposed PSG "young Guatemalan women forced into prostitution" is a cognizable particular social group	The group is not defined solely by persecution because members share immutable traits (young, Guatemalan, women), analogous to Cece	The group is circularly defined by the risk or experience of persecution and lacks a non-persecutory narrowing characteristic	Affirmed: group is circular and non-cognizable under INA (fails immutability/narrowing requirement)
Whether the court can review IJ findings on credibility, corroboration, and timeliness	Seeks reversal of IJ findings as alternative bases for relief	BIA expressly declined to address those findings; some claims unexhausted	Court lacked jurisdiction to review those issues because the BIA did not adopt or address them and some claims were unexhausted

Amezcua-Preciado v. U.S. Att’y Gen., 943 F.3d 1337 (11th Cir. 2019) (PSG must have an immutable characteristic other than the persecution; groups defined by the persecution alone are impermissibly circular)
Cece v. Holder, 733 F.3d 662 (7th Cir. 2013) (en banc) (held a particular PSG cognizable where members shared immutable traits in addition to being targets of prostitution)
Perez-Zenteno v. U.S. Att’y Gen., 913 F.3d 1301 (11th Cir. 2019) (reiterating that circularly defined groups based on risk of persecution are not cognizable)
Rodriguez v. U.S. Att’y Gen., 735 F.3d 1302 (11th Cir. 2013) (rejected PSGs whose defining attribute is persecution by criminal organizations)
Castillo-Arias v. U.S. Att’y Gen., 446 F.3d 1190 (11th Cir. 2006) (PSG not cognizable where defining attribute is persecution by a cartel)
D-Muhumed v. U.S. Att’y Gen., 388 F.3d 814 (11th Cir. 2004) (withholding of removal requires a more stringent showing than asylum)
Rreshpja v. Gonzales, 420 F.3d 551 (6th Cir. 2005) (age and attractiveness did not sufficiently narrow a PSG of women targeted for prostitution)