Morgan v. Blanche — 1st Cir. (Oct 7, 2026)
The First Circuit hears Morgan versus Blanche, a case about protection against return to Jamaica under the Convention Against Torture. Morgan says uniformed police officers beat him in January two thousand twenty-one and told him to pay gang dues or leave his community. He links that attack to a gang that was extorting him. He also faces murder charges in Jamaica, which he describes as a frame-up. In two thousand twenty-four, this court upheld a crime-based bar to his asylum and withholding claims, but sent his request for deferral of removal back because the immigration agency had used an unduly narrow test for official acquiescence. That term concerns officials being aware of torture beforehand and then breaching their legal duty to intervene to prevent it. Officials need not actively cooperate with the torturers, but ineffective policing alone does not necessarily establish acquiescence. The distinction matters when someone seeks protection from torture by a private gang rather than only by government officials. The question is when a police response, or failure to respond, meets that standard. In the recording, IJ means immigration judge, and BIA means Board of Immigration Appeals. Chelsea Eddy will speak for Morgan, and Matthew Spurlock for the government.
Morgan v. Blanche (No. 26-1163) — U.S. Court of Appeals for the First Circuit, argued October 7, 2026.
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