9th Circuit denied Honduran woman's petition for asylum, ruling that robberies she suffered were motivated…
Alicia Reyes Chavez v. Todd Blanche
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9th Circuit denied Honduran woman's petition for asylum, ruling that robberies she suffered were motivated by money, not her family status as an abandoned child.
Why it matters
The Ninth Circuit upheld the Board of Immigration Appeals' decision denying asylum, withholding of removal, and protection under the Convention Against Torture to Alicia Reyes Chavez, a Honduran citizen. Chavez argued she faced harm because she belonged to a particular social group of Honduran female minor children abandoned by family and without surrogate support, but the court found the evidence showed her attackers were motivated by money and a desire to control the community, not her group membership. Because there was no connection between the harm she suffered and a protected characteristic, her claims failed.
Who it affects
This ruling directly affects Alicia Reyes Chavez and her immigration case. More broadly, it reflects the legal standard applied to immigrants from Honduras and elsewhere who seek asylum based on harm from criminals, particularly when the harm appears motivated by money or general violence rather than a protected personal characteristic.
What happens next
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Decision issued Jul 20, 2026
Unpublished opinion
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- Decision issued Jul 20, 2026Unpublished opinion
- Possible rehearingParties can ask the same court to reconsider.
- Possible Supreme Court petitionThe Supreme Court takes only a small share of petitions.
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Jul 20, 2026 · Unpublished opinion
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DEEPER READ
Alicia Michelle Reyes Chavez, a native and citizen of Honduras, sought asylum, withholding of removal, and protection under the Convention Against Torture after suffering three attempted robberies in her home community. She argued that she was targeted because she belonged to a particular social group defined as 'Honduran female minor children abandoned by family and without other surrogate support,' since her parents had moved to the United States and left her behind. An immigration judge denied her claims, and the Board of Immigration Appeals dismissed her appeal. She then petitioned the Ninth Circuit for review. The central legal question was whether there was a connection, called a 'nexus,' between the harm Chavez experienced and a protected ground under immigration law. To qualify for asylum, an applicant must show that a protected characteristic was a central reason for the harm they faced or fear. The court applied a 'substantial evidence' standard, meaning it would uphold the agency's decision unless the evidence compelled a different conclusion. The court found that substantial evidence supported the conclusion that no such nexus existed. Chavez herself testified that the criminals targeted her and others because they wanted money and wanted to exercise control over the town. During one of the incidents, she was with friends who still lived with their parents, yet those individuals were targeted too, suggesting the attackers were indiscriminately motivated by money rather than by Chavez's family situation. The court noted that a desire to be free from criminals motivated by theft or random violence does not connect to a protected ground under the law. Because the court found no nexus at all between the harm and a protected ground, it also upheld the denial of withholding of removal, noting that even the less demanding standard for that claim cannot be met when there is simply no connection. The court also noted that Chavez did not challenge the denial of her Convention Against Torture claim in her opening brief, so that argument was considered waived. The three-judge panel was unanimous, and the opinion is marked as not appropriate for publication and not binding precedent except under a specific circuit rule.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 20 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT ALICIA MICHELLE REYES CHAVEZ, No. 17-72597 Petitioner, Agency No. A206-644-665 v. MEMORANDUM* TODD BLANCHE, Acting Attorney General, Respondent. On Petition for Review of an Order of the Board of Immigration Appeals Submitted July 15, 2026** Before: McKEOWN, OWENS, and LEE, Circuit Judges. Alicia Michelle Reyes Chavez, a native and citizen of Honduras, petitions for review of the Board of Immigration Appeals’ (“BIA”) decision dismissing her appeal from an immigration judge’s decision denying asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”). “We * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). review the denial of asylum, withholding of removal and CAT claims for substantial evidence.” Duran-Rodriguez v. Barr, 918 F.3d 1025, 1028 (9th Cir. 2019). “Under this standard, we must uphold the agency determination unless the evidence compels a contrary conclusion.” Id. As the parties are familiar with the facts, we do not recount them here. We deny the petition for review. 1. An asylum applicant “must demonstrate a nexus between her past or feared harm and a protected ground.” Garcia v. Wilkinson, 988 F.3d 1136, 1143 (9th Cir. 2021). “Specifically, the protected characteristic must be ‘a central reason’ for the past or feared harm.” Id. (citation omitted). A non-citizen’s “desire to be free from harassment by criminals motivated by theft or random violence” bears no nexus to a protected ground. Zetino v. Holder, 622 F.3d 1007, 1016 (9th Cir. 2010). Substantial evidence supports the BIA’s determination that Chavez failed to establish a nexus between any past or feared harm and her proposed particular social group, “Honduran female minor children abandoned by family and without other surrogate support.” Chavez primarily relies on three different attempted robberies by criminals who routinely terrorized her community. During these incidents, the assailants only threatened her and demanded payment. Chavez argues that she may have been targeted, in part, because her parents left her behind to move to the United States. However, she testified that she did not know the 2 criminals outside of these incidents and failed to provide any significant testimony indicating that they would have known her parents were in the United States. Instead, she testified that these men targeted her “because they wanted money” and to exercise their control over the people of the town. Additionally, during the third incident, Chavez was accompanied by friends who lived with their parents, yet the criminals still targeted the group. This suggests that the assailants were indiscriminately motivated by a desire for money, not by Chavez’s proffered particular social group. See Delgado-Ortiz v. Holder, 600 F.3d 1148, 1151 (9th Cir. 2010) (per curiam) (“Asylum is not available to victims of indiscriminate violence, unless they are singled out on account of a protected ground.”). 2. While the nexus standard for withholding of removal is less demanding than for asylum, there is no distinction when there is “no nexus at all.” Barajas- Romero v. Lynch, 846 F.3d 351, 360 (9th Cir. 2017). Because substantial evidence supports that there was no nexus at all, we also uphold the BIA’s denial of Chavez’s withholding of removal claim.1 PETITION DENIED. 1 Chavez waived any challenge to the denial of her CAT claim because she failed to raise it in her opening brief. See Velasquez-Gaspar v. Barr, 976 F.3d 1062, 1065 (9th Cir. 2020). 3
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