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)
24-1699•Juana Garcia Rodriguez v. TODD W. BLANCHE, Acting Attorney General of the United States
24-1699Court of Appeals for the Seventh CircuitJun 12, 2026
United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Argued June 2, 2026
Decided June 12, 2026
Before
CANDACE JACKSON-AKIWUMI, Circuit Judge
JOHN Z. LEE, Circuit Judge
REBECCA TAIBLESON, Circuit Judge
No. 24-1699
JUANA GARCIA RODRIGUEZ, et al.,
Petitioners,
v.
TODD W. BLANCHE, Acting Attorney
General of the United States,
Respondent.1
Petition for Review of an Order of the
Board of Immigration Appeals.
Nos. A206-913-896, A206-913-897,
A206-913-898, A206-913-899
O R D E R
Juana Garcia Rodriguez and three of her children, all Mexican citizens, petition
for review of the Board of Immigration Appeals’ dismissal of their appeal from an
immigration judge’s denial of Garcia Rodriguez’s applications for asylum and
withholding of removal. Garcia Rodriguez argues that the Board incorrectly ruled that
she had not established a nexus between a protected ground and past harm. Because
1 Todd W. Blanche is substituted as the respondent. See F ED. R. A PP . P. 43(c)(2).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1
-- 1 of 5 --
No. 24-1699 Page 2
substantial evidence supports the Board's conclusion that Garcia Rodriguez did not
establish nexus, we deny the petition.
In 2014, the Department of Homeland Security initiated removal proceedings
against Garcia Rodriguez and her three foreign-born daughters, charging each of them
as inadmissible under 8 U.S.C. § 1182(a)(7)(A)(i)(I) as immigrants who were not in
possession of valid entry documents when they applied for admission. Garcia
Rodriguez and her daughters conceded the charges of removability and filed
applications for asylum, withholding of removal, and protection under the regulations
implementing the Convention Against Torture. See 8 U.S.C. §§ 1158(b)(1)(A),
1231(b)(3)(A); 8 C.F.R. §§ 1208.16–1208.18. Garcia Rodriguez asserted that she had
experienced an attempted kidnapping and an extortion threat in Mexico, and she feared
similar harm would befall her or her daughters upon their return. She attributed the
harm she had experienced to her membership in two social groups: the Garcia
Rodriguez family and workers at the San Jose Catholic Church where she was
previously employed.
The immigration judge (IJ) made the following findings of fact, which Garcia
Rodriguez does not challenge on appeal. Garcia Rodriguez and three of her daughters
were born in Mexico (her fourth daughter was born in the United States). In 2014, while
Garcia Rodriguez was living in Hidalgo, Mexico, she was walking home from work
when two men in a truck drove slowly by her. One of the men reached out from the
door in an attempt to grab her and said something to the effect of “[Y]ou’re coming
with us.” She managed to evade the men by running away. Garcia Rodriguez did not
know or recognize the men, and she never saw them again.
A little over a month later, Garcia Rodriguez received a phone call from a male
voice, which she did not recognize, demanding 150,000 pesos and threatening to kidnap
and kill Garcia Rodriguez or her daughters if she did not comply. During the call, the
voice identified by name the church where Garcia Rodriguez worked, her daughters,
and their school. She suspected that she was targeted for extortion because she was
employed at the church and the caller thought she could pay that amount. She did not
know whether either of the other two women she worked with received similar threats.
The following month, Garcia Rodriguez received a phone call from the voice of a
young girl saying, “[M]ommy, help me.” She did not recognize the voice but, fearing
that one day she may receive a similar call from one of her daughters, Garcia Rodriguez
decided to leave Mexico with her three children. On November 1, 2014, they left for the
United States.
-- 2 of 5 --
No. 24-1699 Page 3
Garcia Rodriguez speculated that the caller demanding payment was affiliated
with a cartel or organized crime, but she did not know this for a fact. Based on that fear,
she believed she would not be safe anywhere in Mexico. Since these incidents, Garcia
Rodriguez has not received any additional threats, and neither she nor her daughters
have suffered any physical harm.
The IJ denied the applications, concluding that Garcia Rodriguez had not
demonstrated a nexus between the harm she experienced and a protected ground. The
IJ reasoned that even if the two social groups (her family and employees of her church)
were legally cognizable, she had not submitted any evidence that she was targeted
because of her membership in these groups. Instead, the IJ determined, the threats
Garcia Rodriguez experienced were apparently motivated by her perceived ability to
pay, reflecting a motive of ordinary crime that is insufficient to satisfy the nexus
requirement. The IJ also concluded that Garcia Rodriguez had not established that she
had suffered past persecution because the past harm she suffered was not sufficiently
serious to qualify: She was never physically harmed and the threats she received did
not pose an imminent risk of death or grave harm. In the absence of past persecution,
she was not entitled to a presumption of a well-founded fear of future persecution. And
because her concerns, while subjectively genuine, were based on speculation about
organized crime generally, she also failed to establish a well-founded fear of future
persecution independent of her past harm. For those reasons, the IJ denied Garcia
Rodriguez’s asylum application and, for the same reasons, concluded that she had not
established eligibility for withholding of removal to Mexico.2
The Board of Immigration Appeals agreed with the IJ’s decision and dismissed
the appeal. The Board concluded that Garcia Rodriguez had not demonstrated that she
was targeted based on her membership in either social group, and it agreed with the IJ
that the caller was motivated by furthering a criminal enterprise as opposed to animus
toward members of either proposed particular social group. The Board did not reach
Garcia Rodriguez’s remaining arguments.
Garcia Rodriguez maintains that the Board and the IJ erred in denying her and
her children’s applications for asylum and withholding of removal. Garcia Rodriguez
first maintains that the Board was required to determine whether she had experienced
past persecution. But she is incorrect. The Board need not make findings on issues that
2 The Board also denied Garcia Rodriguez’s claims under the Convention
Against Torture; she does not challenge this denial in her petition for review.
-- 3 of 5 --
No. 24-1699 Page 4
are unnecessary if the nexus question is dispositive. INS v. Bagamasbad, 429 U.S. 24, 25
(1976); Diaz Mejia v. Garland, 74 F.4th 896, 898 (7th Cir. 2023). To establish eligibility for
both asylum and withholding of removal, Garcia Rodriguez was required to
demonstrate a nexus between her feared future harm and her membership in a
particular social group, so the Board’s conclusion that she failed to do so was
dispositive. See 8 U.S.C. § 1158(b)(1)(A); Lopez v. Sessions, 859 F.3d 464, 468 (7th Cir.
2017) (explaining that it was unnecessary to reach petitioner’s arguments regarding his
proposed social groups because a no-nexus finding was dispositive). Because Garcia
Rodriguez failed to show that any past harm was on account of a protected ground,
there was no need for the Board to address whether it was sufficiently severe to
constitute persecution.
Garcia Rodriguez argues next that the Board erred in finding that there was no
nexus to a protected ground. She notes that when she received the extortion call, the
caller mentioned personal details related to her family, including her children’s names
and the name of their school, as well as the fact that she worked at San Jose Catholic
Church. These details, she contends, prove that the caller targeted her because of her
family or her employment at the church.
We review the Board’s nexus determination for substantial evidence,
de Paz-Peraza v. Bondi, 140 F.4th 390, 394 (7th Cir. 2025), and the agency’s finding of fact
is conclusive “unless any reasonable adjudicator would be compelled to conclude to the
contrary,” Meraz-Saucedo v. Rosen, 986 F.3d 676, 684 (7th Cir. 2021) (quoting Nasrallah v.
Barr, 590 U.S. 573, 584 (2020)). Here, substantial evidence supports the Board’s
conclusion that Garcia Rodriguez failed to establish a nexus to her family or
employment. To establish nexus based on family membership, the applicant must prove
that “family membership was the motivation for the persecution.” Ferreyra v. Barr,
962 F.3d 331, 337–38 (7th Cir. 2020); see also Meraz-Saucedo, 986 F.3d at 685. Garcia
Rodriguez makes no argument that the attempted kidnapping was related to either her
family or her employment. And as for the extortionist call, Garcia Rodriguez argues that
she can establish nexus because the caller identified personal details about her place of
work and her daughters’ names and school. But the IJ concluded that this evidence was
insufficient to demonstrate that the threat was directed at her because of animus toward
her family, and the record as a whole does not compel the conclusion that this
determination was wrong. See Casas v. Garland, 47 F.4th 548, 553 (7th Cir. 2022) (record
did not compel a finding of nexus where petitioner could not identify the reason why
other family members were targeted).
-- 4 of 5 --
No. 24-1699 Page 5
To establish nexus based on occupation, the applicant must show that the
persecutor was motivated by animus against that occupation; this motive must be
distinct from the applicant’s perceived wealth. See Granados Arias v. Garland, 69 F.4th
454, 464–65 (7th Cir. 2023). Substantial evidence supports the Board’s decision to
dismiss the appeal based on a failure of proof. The record does not compel the
conclusion that Garcia Rodriguez established that the extortionists were motivated by
animus against employees of her church: Garcia Rodriguez’s own testimony suggesting
that the extortionist thought she would be able to pay because she worked hard
supports the conclusion that the threat was motivated by her perceived wealth.
Finally, Garcia Rodriguez asserts that the Board, in observing that the caller was
motivated by general criminality, effectively required Garcia Rodriguez to show that
animus based on a protected ground was the caller’s sole motive. This, she contends,
flouts our precedent that a persecutor may act with mixed motives. But Garcia
Rodriguez misinterprets the Board’s decision. The Board did not conclude that, because
the perpetrator had mixed motives, Garcia Rodriguez could not establish a nexus.
Rather, the Board concluded that Garcia Rodriguez “did not establish she was targeted
on account of either particular social group,” and it added that the caller’s criminal
motivation was insufficient to satisfy the nexus requirement. In other words, the Board
concluded that Garcia Rodriguez’s evidence failed to meet her burden of proof. That
conclusion is supported by substantial evidence.
We therefore DENY the petition for review.
-- 5 of 5 --
Connect Omnilex to search the legal corpus from your AI assistant.