Rabanales v. Holder
November 30, 2009
**Nexus, social group, gangs**
Petitioner failed to establish that she suffered harm from gang members in Guatemala on account of a protected ground because resistance to gang activity is not a particular social group and personal retribution is not persecution on account of a protected ground.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/11/30/08-73196.pdf
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