Ambiguous “Get Even” Statements and Criminal Motive Support a No-Nexus Finding Under Substantial-Evidence Review

1) Introduction

Case: Cinia Quiroz-Bardales v. Pamela J. Bondi (7th Cir. Dec. 29, 2025) (nonprecedential).
Parties: Petitioners Cinia Quiroz-Bardales (a Honduran citizen) and two minor children sought review of the Board of Immigration Appeals’ (“BIA” or “Board”) order; Respondent is the U.S. Attorney General.
Procedural posture: After the Department of Homeland Security initiated removal proceedings (inadmissibility under 8 U.S.C. § 1182(a)(6)(A)(i)), Petitioners applied for asylum and withholding of removal (and CAT protection, later waived on appeal). The immigration judge (“IJ”) denied relief; the BIA dismissed the appeal; Petitioners sought review in the Seventh Circuit.

Core issue in the Seventh Circuit: Whether substantial evidence supported the BIA’s determination that Petitioners failed to prove a required nexus—that the 2018 attack on Quiroz-Bardales was “on account of” her membership in a protected group (here, the family of her domestic partner, Luis Barahona), and that family membership was “one central reason” for the harm.

Key factual theme: A 2015 robbery/attack on Barahona in one town, followed by a 2018 robbery/attack on Quiroz-Bardales in another town. Assailants asked about Barahona and said they wanted to “get even,” but also stole money and appeared motivated by criminal ends.

2) Summary of the Opinion

The Seventh Circuit denied the petition for review. It held that:

The court would review only the BIA’s opinion because the Board issued its own opinion rather than expressly adopting the IJ’s decision.
Because the BIA addressed only the nexus issue, other topics the IJ discussed (past persecution, future fear, internal relocation, and state protection) were outside the scope of judicial review in this petition.
Under the substantial evidence standard, the record did not compel a finding that family membership was “one central reason” for the 2018 attack; the BIA reasonably found the assailants’ primary motive was to further a criminal enterprise.

3) Analysis

A) Precedents Cited

i) Scope of review: BIA opinion vs. IJ opinion

Gamero v. Barr, 929 F.3d 464 (7th Cir. 2019) and Vahora v. Holder, 626 F.3d 907 (7th Cir. 2010)
The court relied on these cases for a key administrative-law principle in immigration review: when the BIA issues its own opinion rather than adopting or expressly supplementing the IJ, the court reviews the BIA’s reasoning alone. This framing materially narrowed the appellate inquiry to the single issue the BIA addressed—nexus—excluding the IJ’s other alternative grounds.

ii) Standard of review: substantial evidence and “compelled” reversal

Granados Arias v. Garland, 69 F.4th 454 (7th Cir. 2023)
Cited for the proposition that a nexus determination is reviewed for substantial evidence, and (as the court later notes) that the same nexus requirement applies to withholding of removal.
Meraz-Saucedo v. Rosen, 986 F.3d 676 (7th Cir. 2021) (quoting) Nasrallah v. Barr, 590 U.S. 573 (2020)
These cases supply the governing “compelled to conclude to the contrary” formulation: agency findings are conclusive unless any reasonable adjudicator would be compelled to disagree. This is the doctrinal backbone for affirmance in close motive-evidence cases.
Munoz-Rivera v. Garland, 81 F.4th 681 (7th Cir. 2023)
The court invoked this decision to underscore that the petitioner must show the evidence compels a nexus finding—i.e., that “no reasonable adjudicator” could disagree. The opinion uses this as the final checkpoint: even credible testimony can fall short if it does not compel the inference of a protected-ground motive.

iii) Nexus doctrine: “one central reason” and mixed motives

W.G.A. v. Sessions, 900 F.3d 957 (7th Cir. 2018)
This is the principal Seventh Circuit comparator. The court uses it for two related points:
1. Mixed motives are allowed: a criminal motive does not automatically negate a protected-ground motive if the protected ground is “one central reason.”
2. Timing and concrete indicators of motive matter: the opinion contrasts the three-year gap here with W.G.A., where gang targeting occurred two days after a brother defected—facts that supported a stronger inference of family-based motive.
In re J-B-N- & S-M-, 24 I. & N. Dec. 208 (BIA 2007)
Cited for the BIA’s articulation of “one central reason”—it need not be the only reason for harm, but it cannot be minor. This anchors the statutory “one central reason” phrase (8 U.S.C. § 1158(b)(1)(B)) in a familiar administrative gloss applied across asylum cases.

iv) What “compels” nexus: patterns and clear statements

Mejia v. Bondi, 144 F.4th 965 (7th Cir. 2025), Gonzalez Ruano v. Barr, 922 F.3d 346 (7th Cir. 2019), and W.G.A. v. Sessions, 900 F.3d 957 (7th Cir. 2018)
The court distinguishes these cases to explain what stronger nexus evidence looks like: repeated targeting of family members, a clearer pattern of persecution, and multiple unequivocal statements of intent by persecutors. Against that backdrop, the two “ambiguous statements” here (“where is Barahona” and “get even”) were deemed insufficient to compel a protected-ground motive finding.

B) Legal Reasoning

Issue selection and narrowing (administrative review mechanics): Because the BIA did not “expressly adopt” the IJ’s decision, the court confined itself to what the BIA actually decided. As a result, Petitioners could not obtain review of IJ findings the BIA did not discuss (past persecution, future fear, relocation, state protection).
Protected ground and the missing link: The government did not contest that “Barahona’s family” is a cognizable “particular social group,” so the dispute turned not on group definition but on motive—whether the attackers harmed Quiroz-Bardales “on account of” that family membership, and whether it was “one central reason.”
Criminality vs. persecution (and the mixed-motive bridge): The court recognized that criminal motive does not categorically defeat asylum; a protected ground can still be central even where criminals also seek money. But the court agreed the BIA could reasonably find, on this record, that the assailants’ primary purpose was to further a criminal enterprise.
Why the evidence did not compel a nexus finding: The court highlighted several features that permitted (even if did not require) the agency’s inference:
- Temporal separation: a three-year gap between the 2015 attack on Barahona and the 2018 attack on Quiroz-Bardales weakened the claim of a continuing vendetta “one central reason” for targeting her.
- Ambiguity of statements: asking about Barahona and saying they wanted to “get even” did not necessarily indicate family-based animus; it could reflect an attempt to locate him in aid of criminal aims.
- Petitioner’s own understanding: Quiroz-Bardales testified she was unaware of any motive beyond “just getting money,” supporting the agency’s view that robbery/criminal conduct predominated.
- Comparative proof: unlike cases where nexus was compelled, the record lacked robust evidence such as systematic attacks on multiple family members or repeated, explicit statements tying harm to family status.
Under substantial evidence review, these features meant a reasonable adjudicator could agree with the BIA; therefore, reversal was not permitted.
Withholding of removal rises and falls with the same nexus defect: Citing Granados Arias v. Garland, the court reiterated that withholding requires the same nexus showing, so the failure to prove nexus defeated both asylum and withholding.

C) Impact

Although labeled a NONPRECEDENTIAL DISPOSITION (and “to be cited only in accordance with FED. R. APP. P. 32.1”), the order is still informative as a practical application of existing Seventh Circuit doctrine:

Reinforces the evidentiary burden in family-based claims where crime is salient: Petitioners must present motive evidence strong enough to do more than suggest family relevance; they must show it is “one central reason,” not a peripheral detail in an opportunistic robbery.
Demonstrates how appellate scope can narrow arguments: If the BIA decides only one issue, petitioners may lose meaningful appellate review of other IJ findings unless those are preserved and addressed by the Board.
Signals what “nexus-compelling” records often contain: Patterns of family-targeting, multiple incidents across relatives, and clear persecutor statements linking harm to family status—comparators explicitly pointed out via Mejia v. Bondi, Gonzalez Ruano v. Barr, and W.G.A. v. Sessions.

4) Complex Concepts Simplified

Nexus (“on account of”): The required connection between the harm and a protected ground (race, religion, nationality, political opinion, or “particular social group”). It is not enough that harm occurred; the reason for harm matters.
“One central reason”: A protected ground need not be the only reason the persecutor acted, but it must be a major reason—not minor, incidental, or tangential.
Substantial evidence review: A highly deferential standard. The court does not ask whether it would reach the same decision, but whether the record compels the opposite conclusion—i.e., whether any reasonable adjudicator would have to rule for the petitioner.
Particular social group (family): In many asylum systems, “family” can qualify as a protected social group. Here, that point was not contested; the dispute was whether family membership actually motivated the attackers.
Nonprecedential disposition: The court resolves the parties’ dispute but does not create binding circuit precedent; it may still be cited under Rule 32.1 subject to local rules and persuasive-weight limits.

5) Conclusion

The Seventh Circuit’s decision underscores two recurring realities in asylum litigation. First, when the BIA issues its own opinion, judicial review typically tracks only what the BIA addressed, which can sharply limit appellate arguments. Second, in family-based claims arising amid robbery and other criminal conduct, petitioners must marshal motive evidence that does more than raise suspicion—under substantial evidence review, ambiguous references to a relative and generalized threats may not compel a conclusion that family membership was “one central reason” for the harm. The petition was denied because the record permitted the BIA’s view that criminal objectives predominated and nexus was not proven.