Zetino v. Holder
9th Cir.
622 F.3d 1007 (9th Cir. 2010)
2010
Holding
An alien's desire to be free from harassment by criminals motivated by theft or personal malice does not implicate a protected ground; gang violence motivated by personal animus or desire for criminal profit does not establish nexus.
Practitioner Note
Frequently cited for the proposition that criminal motivation breaks the nexus to a protected ground.
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 Case law changes — confirm this decision has not been overruled, limited, or superseded.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.