Personal Animus / Criminal vs. Protected Ground

622 F.3d 1007 (9th Cir. 2010) · 2010

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.

Frequently cited for the proposition that criminal motivation breaks the nexus to a protected ground.