Ismael Torrijos-Zamora v. PAMELA J. BONDI, Attorney General of the United States

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Argued February 26, 2026
Decided March 9, 2026
Before
FRANK H. EASTERBROOK, Circuit Judge
MICHAEL Y. SCUDDER, Circuit Judge
AMY J. ST. EVE, Circuit Judge
No. 25-1739
ISMAEL TORRIJOS-ZAMORA,
Petitioner,
v.
PAMELA J. BONDI, Attorney General
of the United States,
Respondent.
Petition for Review of an Order of the
Board of Immigration Appeals.
No. A215-641-188
O R D E R
Ismael Torrijos-Zamora, a native and citizen of Mexico, challenges the denial of
his claims for asylum, withholding of removal, and protection under the Convention
Against Torture (“CAT”). He argues the Board of Immigration Appeals (“Board”)
improperly rejected his showing of a nexus and ignored evidence justifying relief under
CAT. We disagree and deny his petition for review.
Torrijos-Zamora based his applications for relief on his experiences from
November 2017 to July 2018 in La Loma, Mexico, a town of about 1,000 people. At a
hearing on his claims before an Immigration Judge (“IJ”), Torrijos-Zamora described his
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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leadership in various civic activities in La Loma. This leadership included working with
adults to repaint and landscape public areas, rewarding children for picking up litter,
and arranging meetings with community members to discuss the importance of voting
thoughtfully. He also organized sports games for young boys with the hope of steering
them away from gangs.
Torrijos-Zamora testified that members of one gang, the huachicoleros, began
attending the sports games. They took boys from the games, told Torrijos-Zamora to
“stop what [he] was doing,” and on several occasions threatened to kill him. In
February 2018, gang members began intimidating Torrijos-Zamora by shooting their
firearms into the sky outside his parents’ home every two or three days. As the gang’s
death threats continued, he brought his concerns to the police. They offered a police
patrol, but Torrijos-Zamora said officers began intimidating him by pretextually
stopping him while driving. In one incident, an officer laughed after someone in an
SUV almost collided with Torrijos-Zamora’s car. Torrijos-Zamora believes, from these
experiences and the gang’s involvement in fuel theft, that police officers collaborate
with the huachicoleros.
During the government’s examination, Torrijos-Zamora admitted he had never
been physically harmed while in Mexico. He also confirmed that the gang was targeting
him because “they felt that [he] was taking their local boys away from their gang”—
boys that the gang relied upon for fuel theft.
In August 2018, after leaving La Loma the prior month, Torrijos-Zamora entered
the United States on foot without authorization. Federal officers immediately
apprehended Torrijos-Zamora and detained him. After his release on bond pending his
removal proceedings, Torrijos-Zamora conceded removability but filed applications for
asylum and withholding of removal. He claimed persecution on account of his political
opinion and his membership in two particular social groups: “anti-corruption activists”
and “community organizers who dissuade children from joining gangs.” He also
sought protection under CAT.
The IJ found Torrijos-Zamora’s claims failed on a number of independent
grounds. First, the IJ concluded Torrijos-Zamora did not show harm reaching past
persecution or a well-founded fear of future persecution given weak evidence the gang
would act upon its threats and Torrijos-Zamora’s physical safety in Mexico. Second, the
IJ found that even if Torrijos-Zamora had shown the requisite harm, his evidence did
not show a nexus between that harm and his political opinion or particular social
groups; the IJ noted that, to the contrary, Torrijos-Zamora’s own testimony indicated

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gang members targeted him to further the gang’s enterprise—motivations untethered to
a legally protected ground. Third, the IJ found Torrijos-Zamora failed to show he could
not reasonably relocate within Mexico to avoid future harm. After denying his asylum
claim on those bases, the IJ denied Torrijos-Zamora’s claim for withholding of removal
for the “same reasons.” The IJ also denied Torrijos-Zamora’s CAT claim because he did
not show a requisite likelihood he would face torture upon return to Mexico or that
generalized government corruption would manifest as acquiescence to his torture. The
IJ therefore ordered Torrijos-Zamora’s removal to Mexico.
The Board affirmed the IJ’s ruling. It rested its decision regarding the claims for
asylum and withholding of removal on Torrijos-Zamora’s failure to meet the nexus
requirement. Its analysis largely echoed the IJ’s reasoning. The Board also summarily
affirmed the IJ’s denial of CAT relief. Torrijos-Zamora then petitioned for our review.
See 8 U.S.C. § 1252(b)(2).
“We review the immigration judge’s order as modified by the Board.” Martinez-
Martinez v. Bondi, 147 F.4th 831, 835 (7th Cir. 2025) (citing Meza v. Garland, 5 F.4th 732,
735 (7th Cir. 2021)). In doing so, “[w]e review legal determinations de novo and uphold
factual findings so long as they are supported by substantial evidence.” Mateo-Mateo v.
Garland, 124 F.4th 470, 474 (7th Cir. 2024) (citing Borjas Cruz v. Garland, 96 F.4th 1000,
1004 (7th Cir. 2024)). When reviewing for substantial evidence, we only ask whether
there is “such relevant evidence as a reasonable mind might accept as adequate to
support a conclusion.” Urias-Orellana v. Bondi, 607 U.S. ---- (2026), No. 24-777, 2026 WL
598435, at *4 (U.S. Mar. 4, 2026) (quoting Biestek v. Berryhill, 587 U.S. 97, 103 (2019)). This
review is deferential because the Immigration and Nationality Act provides that
“administrative findings of fact are conclusive unless any reasonable adjudicator would
be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B).
“To qualify for asylum, a petitioner must prove that he is ‘unable or unwilling’ to
return to his home country ‘because of persecution or a well-founded fear of
persecution ….’” Meraz-Saucedo v. Rosen, 986 F.3d 676, 685 (7th Cir. 2021) (quoting 8
U.S.C. §§ 1101(a)(42)(A), 1158(b)(1)(A)). Additionally, “[a]n asylum applicant must
show a nexus between … [that] persecution and one of the five protected grounds: race,
religion, nationality, membership in a particular social group, or political opinion.” Id.
(citing Torres v. Mukasey, 551 F.3d 616, 629 (7th Cir. 2008); 8 U.S.C. § 1101(a)(42)(A)).
Under the nexus requirement, claiming harm and the protected ground independently
is insufficient; “[t]he evidence must show that [the protected ground] was the
motivation for the persecution.” Ferreyra v. Barr, 962 F.3d 331, 337–38 (7th Cir. 2020).

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Claims for withholding of removal share the same five protected grounds and nexus
requirement but require a stronger showing of harm. See Martinez-Martinez, 147 F.4th at
836; Granados Arias v. Garland, 69 F.4th 454, 465 (7th Cir. 2023). To show eligibility “[f]or
CAT protection, the applicant must show that it is ‘more likely than not that he or she
will be tortured’ if returned.” Singh v. Garland, 89 F.4th 602, 605 (7th Cir. 2024) (quoting
8 C.F.R. § 1208.16(c)(2) (2025)). Finally, “[a]n applicant’s ability to relocate creates
grounds to reject each of these forms of relief.” Id. (citation modified).
Torrijos-Zamora first claims we should remand because the Board ignored the
possibility that gang members targeted him not only in order to further their enterprise
but also because they opposed his political opinions. As Torrijos-Zamora notes, the
Board may err by ignoring evidence of a valid nexus. See Mohideen v. Gonzales, 416 F.3d
567, 571 (7th Cir. 2005). Torrijos-Zamora does not show, however, that the Board erred
in this case. In its nexus ruling, the Board acknowledged Torrijos-Zamora’s political
activity but reasoned he failed to show the gang even cared about that activity, let alone
persecuted him for it. Instead, the Board highlighted Torrijos-Zamora’s own testimony
that the gang targeted him because he interfered with the gang’s recruitment of young
boys. Harm motivated by a “gang’s recruitment and retaliation goals” does not show a
valid nexus. See de Paz-Peraza v. Bondi, 140 F.4th 390, 394 (7th Cir. 2025) (collecting
cases). Even on appeal, Torrijos-Zamora identifies no evidence that the gang’s conduct
was motivated by his political opinions. He therefore cannot show that the Board
ignored relevant evidence. For the same reason, and because the Board relied on his
own testimony, Torrijos-Zamora does not show the record compels a contrary finding.
Second, Torrijos-Zamora argues the Board only considered the nexus
requirement for his asylum claim, and thus failed to consider whether he showed a
nexus for his withholding-of-removal claim. The record indicates otherwise. The Board
consolidated its analysis of the nexus requirement on the premise that the requirement
applies equally to his claims for asylum and withholding of removal. The Board’s
premise accurately reflected the law. See Granados Arias, 69 F.4th at 465 (“The nexus
requirement … is the same for both asylum and withholding of removal.” (quoting
W.G.A. v. Sessions, 900 F.3d 957, 965 (7th Cir. 2018))). Nor was the Board’s consolidated
analysis impermissible: our own caselaw has adopted a similar approach. See id.; de Paz-
Peraza, 140 F.4th at 395.
Last, Torrijos-Zamora challenges the ruling on his CAT claim by arguing the
Board and IJ ignored country conditions reports demonstrating severe gang violence

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across Mexico.* Again, the record indicates otherwise. The IJ acknowledged the
documentary evidence in its opinion but found that evidence did not establish Torrijos-
Zamora’s entitlement to CAT relief. Indeed, the IJ noted the reports showed that the
gang Torrijos-Zamora feared was geographically limited to areas connected to its fuel
theft enterprise.
Torrijos-Zamora’s argument that the documentary evidence itself demonstrates
he was entitled to protection under CAT fares no better. Under CAT’s rigorous
standards, Torrijos-Zamora had to prove it “more likely than not that he would be
tortured if removed.” See Orellana-Arias v. Sessions, 865 F.3d 476, 489 (7th Cir. 2017). Yet
“evidence of generalized violence … does not show risk that the petitioner will be
targeted specifically.” Nyandwi v. Garland, 15 F.4th 836, 842 (7th Cir. 2021) (citing Barry
v. Barr, 916 F.3d 666, 671 (7th Cir. 2019)); see also Mabuneza v. Garland, 16 F.4th 1222, 1227
(7th Cir. 2021) (“[A CAT applicant] must show that he personally faces a substantial risk
of torture.”). We have therefore repeatedly rejected documentary evidence as sufficient
to make out a CAT claim. See Lozano-Zuniga v. Lynch, 832 F.3d 822, 830–31 (7th Cir. 2016)
(collecting cases).
For the reasons discussed, we DENY Torrijos-Zamora’s petition for review.
* The Board affirmed the IJ’s CAT ruling without modifying its reasoning. We
therefore review the IJ’s opinion concerning this claim. See Orellana-Arias v. Sessions, 865
F.3d 476, 489 (7th Cir. 2017).

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