Central Reason vs. A Reason

846 F.3d 351 (9th Cir. 2017) · 2017

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.

Critical for practitioners: asylum requires 'a central reason'; withholding of removal requires only 'a reason.' This distinction can affect strategy.