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Albarran-Sotelo v. Blanche — 9th Cir. (Sep 14, 2026)

No. 25-5904 Argued September 14, 2026 Published October 6, 2026

The Ninth Circuit hears Luis Albarran-Sotelo's asylum appeal. He was kidnapped by the Jalisco Cartel in Mexico's Guerrero state and held for ransom. An immigration judge accepted that this was past persecution, but denied asylum on the ground that he could live safely elsewhere in Mexico. The Board of Immigration Appeals upheld that decision. Because past persecution was established, the government had to show that relocation within his country would be safe and reasonable. University of Georgia law student Olivia Haas will argue that the agency instead made him disprove his ability to move. He also seeks humanitarian asylum. This is a discretionary alternative for a victim of past persecution: exceptionally severe past abuse, or a reasonable possibility of other serious harm on return, can sometimes justify protection even without future persecution. The central question is whether the agency actually assessed his individual safety, rather than assuming anywhere outside Guerrero would do.

Albarran-Sotelo v. Blanche (No. 25-5904) — U.S. Court of Appeals for the Ninth Circuit, argued September 14, 2026.

Sources
Case record — Ninth Circuit memorandum, October 1, 2026:https://cdn.ca9.uscourts.gov/datastore/memoranda/2026/10/01/25-5904.pdf
Advocate — University of Georgia Appellate Litigation Clinic:https://law.uga.edu/news/80130
Humanitarian asylum — DOJ/DHS regulatory explanation, footnote 208 (2023):https://www.govinfo.gov/content/pkg/FR-2023-02-23/html/2023-03718.htm

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