Case Explained: MATEO-JOAQUIN, ET AL. V. BLANCHE

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-11 The Ninth Circuit denied the petition for review filed by Manuela Mateo-Joaquin and her four children seeking asylum, withholding of removal, and relief under the Convention Against Torture. The court affirmed the Board of Immigration Appeals’ decision based on two primary grounds. First, applying the substantial evidence standard, the court held that there was sufficient evidence to support the finding that Mateo-Joaquin failed to establish past persecution on account of membership in the proposed social group of “Guatemalan women unable to leave a domestic relationship.” The court noted that the Immigration Judge and Board relied on Mateo-Joaquin’s own testimony indicating she could have left her former partner, meaning no reasonable adjudicator would be compelled to conclude she was unable to leave the relationship. Second, the court ruled that the Board did not err in declining to consider a claim based on the social group “Guatemalan women” because Mateo-Joaquin conceded that her former counsel failed to advance this specific argument before the Immigration Judge. Citing *Matter of W-Y-C- & H-O-B-* and Ninth Circuit precedent, the court explained that while the duty to develop the record applies to pro se applicants, it does not apply when an alien is represented by competent counsel who is responsible for advancing all facts and arguments entitling them to relief. Consequently, the petition was denied without reaching the merits of the unraised claim. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.