Ninth Circuit denies petition from Mexican immigrant seeking asylum, ruling that crimes against his family…
Dominguez Parra v. Blanche
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Ninth Circuit denies petition from Mexican immigrant seeking asylum, ruling that crimes against his family were financially motivated, not tied to a protected group, and that he received a fair hearing.
Why it matters
The Ninth Circuit denied Isidoro Dominguez Parra's petition for review of a Board of Immigration Appeals decision upholding an immigration judge's denial of asylum, withholding of removal, and protection under the Convention Against Torture. The court found substantial evidence supported the conclusion that the crimes targeting Parra's family members, including a fake kidnapping report, the killing of his nephew, and an extortion demand, were driven by financial gain rather than any protected characteristic. The court also rejected his due process claim, finding the immigration judge gave him ample opportunity to raise fears related to his multiple sclerosis.
Who it affects
This ruling directly affects Isidoro Dominguez Parra and his immigration status. More broadly, it reflects standards that apply to immigrants from Mexico and elsewhere who seek asylum or CAT protection based on crimes they or their family members experienced, particularly where financial motives are found to drive those crimes.
What happens next
Current
Decision issued Jul 14, 2026
Unpublished opinion
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- Decision issued Jul 14, 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Jul 14, 2026 · Unpublished opinion
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DEEPER READ
Isidoro Dominguez Parra, a Mexican citizen, sought review of a decision by the Board of Immigration Appeals that upheld an immigration judge's denial of asylum, withholding of removal, and relief under the Convention Against Torture (CAT). He argued that his family had been targeted in ways that placed him at risk if returned to Mexico, and that the immigration judge violated his due process rights by not specifically asking about harm related to his multiple sclerosis. On the asylum and withholding claims, the court applied the substantial evidence standard, meaning it would only overturn the agency if the record compelled a different conclusion. The court found that three separate incidents, a 2003 false kidnapping report to his mother, the killing of his nephew during an attempted kidnapping around 2011, and a 2017 extortion demand against his brother, were all motivated by financial gain. Because none were connected to a legally protected characteristic such as race, religion, nationality, political opinion, or membership in a particular social group, Parra did not qualify for asylum or withholding of removal. On the CAT claim, the court noted that aside from the nephew's killing, no other family members suffered physical harm, and several continued to live in Mexico. The court acknowledged Parra presented general evidence of violence and organized crime in Mexico, but stated that generalized evidence of violence and crime is not enough to establish the likelihood of torture required for CAT protection. On the due process claim, the court reviewed the immigration judge's conduct and found it met constitutional requirements. The judge asked open-ended questions about what would happen to Parra in Mexico, asked specifically about his multiple sclerosis treatment, and offered him repeated opportunities to raise any fear tied to his medical condition. The court concluded the hearing was not so fundamentally unfair that Parra was prevented from presenting his case. The panel was unanimous and the petition was denied. Because this is a memorandum disposition, it is not precedent and applies only to this case under Ninth Circuit rules.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 14 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT ISIDORO DOMINGUEZ PARRA, No. 21-423 Agency No. Petitioner, A206-547-240 v. MEMORANDUM* TODD BLANCHE, Acting Attorney General, Respondent. On Petition for Review of an Order of the Board of Immigration Appeals Submitted July 10, 2026** Portland, Oregon Before: GRABER, BERZON, and SUNG, Circuit Judges. Petitioner Isidoro Dominguez Parra, a native and citizen of Mexico, timely seeks review of a decision by the Board of Immigration Appeals (“BIA”) dismissing his appeal of an immigration judge’s (“IJ”) denial of relief from * 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). removal. We review for substantial evidence the agency’s denial of asylum, withholding of removal, and relief under the Convention Against Torture (“CAT”). Ani v. Bondi, 155 F.4th 1118, 1126 (9th Cir. 2025). We review de novo whether the IJ violated due process. Olea-Serefina v. Garland, 34 F.4th 856, 866 (9th Cir. 2022). We deny the petition. 1. Substantial evidence supports the BIA’s determination that “the motive for the harm [Petitioner] feared was financial gain that was wholly unrelated to any protected ground.” See Corpeno-Romero v. Garland, 120 F.4th 570, 581 (9th Cir. 2024) (holding that we review for substantial evidence the agency’s determination of motive). Ample evidence supports the conclusion that financial gain motivated the perpetrators of each of the incidents experienced by Petitioner’s family members—a 2003 false report to Petitioner’s mother that Petitioner had been kidnapped, the killing of his nephew during an attempted kidnapping in approximately 2011, and a 2017 extortion demand to Petitioner’s brother. The record does not compel the conclusion that the unknown perpetrators of these disparate events were motivated also by a connection to Petitioner’s family. 2. Substantial evidence supports the agency’s denial of CAT relief. Other than the killing of Petitioner’s nephew in 2011, the record contains no evidence of physical harm to Petitioner’s family members, several of whom have lived in Mexico for many years. Petitioner presented evidence regarding organized crime 2 21-423 and violence in Mexico. But “[g]eneralized evidence of violence and crime is insufficient to establish a likelihood of torture” for the purpose of establishing eligibility for CAT protection. Park v. Garland, 72 F.4th 965, 980 (9th Cir. 2023). The record does not compel the conclusion that Petitioner is likely to be tortured upon return to Mexico. 3. The IJ did not violate Petitioner’s right to due process by failing to inquire specifically about any fear of harm due to Petitioner’s multiple sclerosis. The IJ asked Petitioner an open-ended question about what would happen to him in Mexico; inquired about any medications that Petitioner takes; asked specifically about his treatment for multiple sclerosis; and then asked several more open-ended questions about Petitioner’s fear of harm. We conclude that the IJ’s colloquy, which repeatedly offered Petitioner an opportunity to express a fear of harm due to his medical condition, met the requirements of due process. The proceeding was not “so fundamentally unfair that [Petitioner] was prevented from reasonably presenting [his] case.” Olea-Serefina, 34 F.4th at 866 (quoting Lacsina Pangilinan v. Holder, 568 F.3d 708, 709 (9th Cir. 2009)); see Hussain v. Rosen, 985 F.3d 634, 643–45 (9th Cir. 2021) (holding that the IJ met the requirements of due process by asking open-ended questions that offered the pro se petitioner opportunities to develop his testimony). PETITION DENIED. 3 21-423
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