Barajas-Romero v. Lynch
9th Cir.
846 F.3d 351 (9th Cir. 2017)
2017
Holding
The 9th Circuit applies an 'a reason' nexus standard (not 'a central reason') to withholding of removal claims; the two standards differ, and courts must apply the appropriate one for each form of relief.
Practitioner Note
Critical for practitioners: asylum requires 'a central reason'; withholding of removal requires only 'a reason.' This distinction can affect strategy.
This summary describes what the tribunal held. Always verify the citation and read the full decision before relying on it. Case law changes — confirm this decision has not been overruled, limited, or superseded. Not legal advice.