Matter of J-C-A-G-

BIA

29 I&N Dec. 331 (BIA 2025)

2025

Holding

Applicant who cooperated with U.S. law enforcement against a cartel did not demonstrate a clear probability of torture where fear was based on unsubstantiated statements from a coconspirator and generalized evidence of cartel violence rather than individualized risk.

Practitioner Note

Underscores that CAT protection requires an individualized risk, not merely generalized country violence even for informants against organized crime.

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