Case Explained: SALVADOR PALACIOS PEREZ V. TODD BLANCHE

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-25 The Ninth Circuit denied Salvador Palacios Perez’s petition for review of a Board of Immigration Appeals order denying his application for withholding of removal and relief under the Convention Against Torture. The court held that the agency permissibly determined his proposed particular social group, “Americanized Mexicans,” is not cognizable under Ninth Circuit precedent, citing *Barbosa v. Barr* and *Delgado-Ortiz v. Holder*. Additionally, the court found unexhausted and therefore properly before it any arguments regarding a distinct social group based on his relationship to his niece, as required by the mandatory exhaustion rule of 8 U.S.C. § 1252(d)(1) under *Santos-Zacaria v. Garland*. Regarding the Convention Against Torture claim, the court affirmed the agency’s finding that Perez failed to meet his burden of showing government consent or acquiescence to potential torture, noting he forfeited this issue by failing to meaningfully contest it in his opening brief. Finally, the court rejected Perez’s due process claims, concluding there was no evidence in the record that the proceedings were fundamentally unfair and characterizing his arguments as impermissible re-characterizations of merits-based disputes. As a result of these holdings, the petition is denied and the agency’s order denying relief stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.