Romero Calderon v. Bondi, 24-1578

Francis Romero Calderon and her two minor children, all Honduran nationals, sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the U.S.
The gang Mara Salvatrucha (MS-13) threatened Romero Calderon due to her former partner’s debt, demanding she pay and threatening violence against her and her children.
When Romero Calderon reported the threats and violence to Honduran police, authorities took her complaint and investigated the scene.
An Immigration Judge denied their applications for asylum, withholding of removal, and CAT relief; the Board of Immigration Appeals (BIA) affirmed.
The petitioners requested Ninth Circuit review of the BIA's decision, and the case proceeded without oral argument.
The Ninth Circuit reviewed under the substantial evidence standard and denied the petition for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Nexus to Protected Ground (Asylum/Withholding)	Persecution due to threats and violence from gang related to family member’s debt	Threats were criminal, not based on a protected ground	No nexus established; denial affirmed
Fear of Future Persecution (Withholding)	Risk of future harm based on same circumstances	Harm would not be because of a protected characteristic	No protected reason for fear; denial affirmed
CAT Eligibility	Risk of torture if removed to Honduras, possibly with official acquiescence	Authorities responded appropriately to reports; no evidence of acquiescence	No evidence of official torture or acquiescence; denial affirmed

J.R. v. Barr, 975 F.3d 778 (9th Cir. 2020) (review standards for legal/factual agency decisions in immigration cases)
Singh v. Whitaker, 914 F.3d 654 (9th Cir. 2019) (substantial evidence standard defined in the context of agency review)
Zetino v. Holder, 622 F.3d 1007 (9th Cir. 2010) (no nexus for asylum/withholding where harm is motivated by criminal intent, not protected ground)