Garcia Garcia v. Blanche — 9th Cir. (argued June 26, 2026)
The Ninth Circuit considers when a family qualifies as a particular social group under asylum law. Abel Ricardo Garcia Garcia sought asylum and withholding of removal based on his nuclear family and his close resemblance to a murdered brother. A particular social group must share an immutable characteristic, have clear boundaries, and be recognized as distinct in the relevant society. Garcia says Ninth Circuit precedent treats family as the quintessential example. The government says he still must prove that Mexican society recognizes his family as distinct. After this argument, the court granted his petition in part. It held that the Board of Immigration Appeals wrongly relied on Matter of L-E-A to reject his family group, upheld the rejection of his resemblance group, and denied his Convention Against Torture claim because he had not raised it before the Board.
Garcia Garcia v. Blanche (No. 25-7464) — U.S. Court of Appeals for the Ninth Circuit, argued June 26, 2026.
- 0:00Introduction
- 2:07Robert F. Jacobs
- 5:40Matter of L-E-A
- 14:41Robbin K. Blaya