Rivas-Cruz v. Holder
November 30, 2009
**Nexus, political opinion, social group, MS-13**
Substantial evidence supports the BIA’s conclusion that Rivas-Cruz’s vocal opposition to the MS-13 gang did not constitute a political opinion. Rivas-Cruz’s claim that he is eligible for asylum and withholding of removal based on his membership in the group of young El Salvadorean males who refuse to join gangs also fails because that group does not constitute a particular social group.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/11/30/08-72132.pdf
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