Maria Rodriguez-Tornes v. Merrick Garland, 993 F.3d 743

Maria Luisa Rodriguez Tornes, a Mexican national, testified to lifelong severe abuse by her mother, an estranged husband (Baron), and a later partner (Hernandez) after asserting female equality—abuse included beatings, rapes, burns, and strangulation.
After fleeing to the U.S., returning to Mexico, and then again to the U.S. fearing Hernandez, removal proceedings began in 2017.
The IJ found Rodriguez credible and granted asylum, withholding of removal, and CAT protection, concluding her feminist political opinion and membership in a social group (Mexican females) were reasons for persecution.
The BIA affirmed CAT relief but reversed asylum and withholding, holding the record lacked nexus to a protected ground (relying on Matter of A-B- I), while not disputing credibility or severity of abuse.
The Ninth Circuit held the record compels finding that Rodriguez held (or was imputed) a feminist political opinion and that her abusers persecuted her because of that opinion; it also held the BIA’s CAT determination entails government acquiescence, well‑founded fear, and inability to relocate.
Result: petition granted; case remanded for the Attorney General to exercise discretion on asylum; withholding of removal must be provided if asylum is denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Nexus: Were abuses "on account of" a protected ground (political opinion)?	Rodriguez: her expressed belief in gender equality (feminism) was a central reason abusers harmed her; abusers made explicit statements showing motive.	Gov: abuse arose from personal/relationship motives; no evidence abusers acted for reasons unrelated to the relationship.	Held: Nexus established — record compels that feminist political opinion was at least one central reason.
Does feminism qualify as a political opinion?	Rodriguez: her statements and conduct show a feminist political opinion.	Gov: political opinion must be formal/political activity (implicit).	Held: Feminism constitutes political opinion under circuit precedent.
Government unwilling/unable to control persecutors (acquiescence)?	Rodriguez: IJ found authorities acquiesced; country conditions evidence shows inadequate protection.	Gov: not addressed in depth by BIA because it found no nexus.	Held: BIA affirmed CAT relief; that necessarily shows government would acquiesce and inability/unwillingness to control persecutors.
Relocation and well‑founded fear — does CAT grant resolve these?	Rodriguez: CAT grant shows torture more likely than not, thus implies well‑founded fear and unreasonable internal relocation.	Gov: BIA declined to analyze relocation/well‑founded fear after finding no nexus.	Held: CAT grant resolves well‑founded fear and reasonableness of relocation; no Ventura remand required.

Parussimova v. Mukasey, 555 F.3d 734 (9th Cir. 2009) (defines "central reason" test for nexus)
Ahmed v. Keisler, 504 F.3d 1183 (9th Cir. 2007) (two‑part political‑opinion nexus test: held/attributed opinion and persecutor motivated by it)
Fatin v. I.N.S., 12 F.3d 1233 (3d Cir. 1993) (feminism qualifies as political opinion)
Bringas‑Rodriguez v. Sessions, 850 F.3d 1051 (9th Cir. 2017) (multiple central reasons for persecution allowed)
Baghdasaryan v. Holder, 592 F.3d 1018 (9th Cir. 2010) (nexus requirement overview)
Singh v. Whitaker, 914 F.3d 654 (9th Cir. 2019) (past persecution triggers presumption of well‑founded fear; Ventura remand principles)
Garcia‑Milian v. Holder, 755 F.3d 1026 (9th Cir. 2014) (defines government acquiescence standard)
Cole v. Holder, 659 F.3d 762 (9th Cir. 2011) (acquiescence requires awareness and willful blindness or unwillingness to act)
Guo v. Sessions, 897 F.3d 1208 (9th Cir. 2018) (torture is a more severe form of mistreatment than persecution)
Fedunyak v. Gonzales, 477 F.3d 1126 (9th Cir. 2007) (CAT findings can demonstrate well‑founded fear for asylum purposes)