The AI workspace for legal professionals
- Legal research with access to more than 1 million sources
- Document automation
- Matter management
- Hosted in the EU and Switzerland
Try it free for 14 days (10 questions/day during trial)
The AI workspace for legal professionals
Try it free for 14 days (10 questions/day during trial)
25-1470•Catalina B. Vasquez Escobar; F.p.g.v. v. PAMELA JO BONDI, Attorney General
25-1470Court of Appeals for the Fourth CircuitMar 3, 2026
UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 25-1470
CATALINA B. VASQUEZ ESCOBAR; F.P.G.V.,
Petitioners,
v.
PAMELA JO BONDI, Attorney General,
Respondent.
On Petition for Review of an Order of the Board of Immigration Appeals.
Submitted: February 26, 2026 Decided: March 2, 2026
Before NIEMEYER and QUATTLEBAUM, Circuit Judges, and FLOYD, Senior Circuit
Judge.
Petition denied by unpublished per curiam opinion.
ON BRIEF: Donald L. Schlemmer, Washington, D.C., Alireza Ghazi-Zahedi,
Williamsburg, Virginia, for Petitioners. Brett A. Shumate, Assistant Attorney General,
Shelley R. Goad, Assistant Director, Monica G. Antoun, Office of Immigration Litigation,
Civil Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for
Respondent.
Unpublished opinions are not binding precedent in this circuit.
-- 1 of 3 --
2
PER CURIAM:
Catalina B. Vasquez Escobar and her minor son, natives and citizens of Guatemala,
petition for review of an order of the Board of Immigration Appeals (Board) dismissing
their appeal from the immigration judge’s decision denying Vasquez Escobar’s
applications1 for asylum and withholding of removal.2 We deny the petition for review.
We have reviewed the administrative record, including the transcript of the merits
hearing and all supporting evidence, and considered the arguments raised on appeal in
conjunction with the record and the relevant authorities. We conclude that the record
evidence does not compel a ruling contrary to any of the operative factual findings, see 8
U.S.C. § 1252(b)(4)(B), and that substantial evidence supports the immigration judge’s
pivotal rulings, affirmed by the Board, that Vasquez Escobar (a) did not assert any claim
of past persecution; and (b) advanced a fear of future persecution that hinged exclusively
on generalized conditions of gang violence and unrest prevalent in Guatemala, which “are
insufficient to establish persecution on account of a protected ground,” Tepas v. Garland,
73 F.4th 208, 218 (4th Cir. 2023) (citation modified).
1 Vasquez Escobar’s minor son was a rider on her asylum application, see 8 U.S.C.
§ 1158(b)(3), and is identified as a petitioner in this court by his initials.
2 Vasquez Escobar has forfeited review of the immigration judge’s denial of relief
under the Convention Against Torture, which was not challenged in the administrative
appeal, by not raising that issue in the brief submitted to this court. See Fed. R. App. P.
28(a)(8)(A); Ullah v. Garland, 72 F.4th 597, 602 (4th Cir. 2023) (explaining that a party
forfeits appellate review of those issues and claims not raised in the party’s briefs).
-- 2 of 3 --
3
Accordingly, we deny the petition for review. See In re Vasquez Escobar (B.I.A.
Apr. 4, 2025). We dispense with oral argument because the facts and legal contentions are
adequately presented in the materials before this court and argument would not aid the
decisional process.
PETITION DENIED
-- 3 of 3 --
Connect Omnilex to search the legal corpus from your AI assistant.