Stepwise “Chain-of-Events” Proof in CAT Claims: Seventh Circuit (Nonprecedential) Endorses Link-by-Link Analysis and Clarifies that Forced Labor to Repay a Cartel Debt, Without More, Is Not Torture

Introduction

In C.N.T. v. Bondi, No. 24-1558 (7th Cir. Mar. 25, 2025), a nonprecedential order of the United States Court of Appeals for the Seventh Circuit denies a lawful permanent resident’s petition for review after the immigration judge (IJ) and the Board of Immigration Appeals (BIA) rejected his application for deferral of removal under the Convention Against Torture (CAT). The petitioner, a Guatemalan national who pleaded guilty to a methamphetamine-distribution conspiracy and cooperated with U.S. authorities, asserted that the Sinaloa Cartel would torture and kill him in Guatemala, both because of his cooperation and because he owed a drug debt to the cartel.

The court applies highly deferential substantial-evidence review and upholds the agency on two dispositive links in the causal chain: (1) that it was not more likely than not the cartel would learn of his cooperation, and (3) that it was not more likely than not the cartel would be able to locate him anywhere in Guatemala. Because those links failed, the court declined to address whether the cartel would decide to torture him if it learned of his cooperation (step 2) or whether Guatemalan officials would acquiesce (step 4). The panel also affirmed the IJ’s conclusion that forced labor to repay a drug debt, without more, does not constitute torture.

Although designated nonprecedential, the opinion offers important guidance for presenting and assessing CAT claims involving transnational criminal organizations and alleged “cooperator” risks, particularly on how to structure proof through a stepwise “chain-of-events” analysis and on the evidentiary demands for knowledge and location links.

Summary of the Opinion

- Procedural posture: After completion of his criminal sentence, the Department of Homeland Security initiated removal proceedings. The petitioner conceded removability and sought CAT deferral. The IJ found both the petitioner and his country-conditions expert credible but denied relief. The BIA affirmed, endorsing the IJ’s reasoning. The Seventh Circuit reviewed the IJ’s decision as supplemented by the BIA and denied the petition for review.

- Core holding: Substantial evidence supports the agency’s conclusion that the petitioner failed to establish, by a “more likely than not” probability, two critical links necessary for his theory of future torture: that the Sinaloa Cartel would learn of his cooperation and that it would be able to find him anywhere in Guatemala. Because these links failed, the Seventh Circuit did not reach the remaining links (cartel intent to torture upon learning; official acquiescence). The court further agreed that debt-based forced labor, without additional indicia of severe pain or suffering, is not torture.

- Standard of review: The court applied the “highly deferential” substantial-evidence test and emphasized that it could reverse only if the record compelled the opposite conclusion.

Analysis

Precedents and Authorities Cited

Tchemkou v. Gonzales, 495 F.3d 785, 790 (7th Cir. 2007) — The court reviews the IJ’s decision as supplemented by the BIA’s opinion where the BIA agrees with the IJ’s reasoning.
Borovsky v. Holder, 612 F.3d 917, 920 (7th Cir. 2010) — Explicit words of adoption are not required for the BIA to incorporate the IJ’s decision as part of the agency decision under review.
8 C.F.R. § 1208.16(c)(2) — The CAT standard requires showing it is “more likely than not” the applicant would be tortured upon removal.
Rodriguez-Molinero v. Lynch, 808 F.3d 1134 (7th Cir. 2015) — Frames the CAT inquiry in terms of whether there is a substantial risk of torture if removed, consistent with the “more likely than not” standard.
Mabuneza v. Garland, 16 F.4th 1222, 1226 (7th Cir. 2021) — Reiterates the “highly deferential” substantial-evidence standard and that reversal is warranted only if the record compels a contrary conclusion.
Meraz-Saucedo v. Rosen, 986 F.3d 676, 684 (7th Cir. 2021), quoting Nasrallah v. Barr, 590 U.S. 573, 584 (2020) — Agency findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.
Orellana-Arias v. Sessions, 865 F.3d 476, 489 (7th Cir. 2017) — Applicants bear the burden to show a risk of torture regardless of where in the country of removal they might relocate; internal relocation is a relevant factor in CAT analysis.
8 C.F.R. § 1208.16(c)(3)(iii) — Directs IJs to consider whether the applicant could relocate within the country of removal to avoid torture.
Bernard v. Sessions, 881 F.3d 1042, 1049 (7th Cir. 2018) — Acknowledges that error on a point need not warrant relief if other dispositive grounds sustain the decision (harmless/dispositive-issue principle).
Diaz Mejia v. Garland, 74 F.4th 896, 898 (7th Cir. 2023) — Notes the broad principle in CAT cases that adjudicators may avoid discussing issues that are subordinate to other dispositive issues.

Legal Reasoning and Application

1) Organizing the proof as a “chain of events.” The IJ structured the case around four logical links that would have to be “more likely than not” for the petitioner’s theory of torture to hold:

(1) The cartel will learn he cooperated with law enforcement.
(2) Upon learning this, the cartel will decide to torture him in Guatemala.
(3) The cartel will be able to locate him anywhere in Guatemala.
(4) The torture will occur with the consent or acquiescence of a public official acting in an official capacity.

The Seventh Circuit expressly cautioned that this is not a universal “test” for all CAT applications, but rather an appropriate way to organize the evidence for this particular theory of harm. This articulation matters practically: where a CAT claim turns on a sequence of contingencies, each link must be proven to the “more likely than not” probability threshold. Missing any one link is fatal to relief.

2) Link 1 — Will the cartel learn of the cooperation? The record showed the petitioner’s criminal case was sealed, he gave no open-court testimony, and he had assured cartel-affiliated individuals that he would not cooperate. Although there was evidence that cartel-associated persons inquired about his release date, the court held that such inquiries, without more, did not compel a finding that the cartel would likely deduce actual cooperation. Under deferential review, the IJ/BIA were entitled to conclude the probability did not surpass the “more likely than not” threshold. The panel also clarified a factual point: while the cartel had previously admonished him in general terms not to cooperate (and warned of dire consequences), there was no record evidence that the cartel had discovered his cooperation or issued threats specifically because of his cooperation.

3) Link 3 — Can the cartel find him anywhere in Guatemala? The record confirmed Sinaloa operations and contacts in Guatemala and some governmental infiltration, but the petitioner did not establish that the cartel could specifically locate him in Guatemala or that there would be no safe place for him anywhere in the country. The court emphasized the applicant’s burden to demonstrate a substantial risk of torture irrespective of internal relocation options and cited the regulation requiring consideration of relocation. The events in the record had only a “tenuous connection to Guatemala,” reducing the likelihood of recognition or reporting that would enable the cartel to find him. Substantial evidence thus supported the agency’s finding that the location link failed.

4) Links 2 and 4 — Cartel intent to torture and official acquiescence. Because Links 1 and 3 failed, the court did not reach the remaining links. Relying on Bernard and Diaz Mejia, the Seventh Circuit reiterated that it is permissible to avoid subordinate issues when other dispositive shortcomings resolve the case. As a result, whether the cartel would single him out for torture if it learned of cooperation and whether Guatemalan officials would acquiesce were left undecided.

5) Debt-based forced labor is not, without more, torture. The petitioner also argued that his cartel debt created an independent risk of torture. The court acknowledged record evidence that the cartel knew of the debt and often forces debtors into labor. But forced labor to pay off a debt, “without more,” does not meet the regulatory definition of torture, which requires severe pain or suffering intentionally inflicted for specific purposes and with official involvement or acquiescence. Critically, the record lacked evidence that (a) the cartel would be able to locate him in Guatemala for debt enforcement and (b) debt enforcement in Guatemala, as opposed to punishment of informants, typically entails torture as defined under CAT. The expert’s testimony largely assumed the petitioner would be viewed both as a debtor and an informant—an assumption undercut by the failure of the knowledge and location links.

Why the Substantial Evidence Standard Drove the Outcome

The Seventh Circuit repeatedly underscored that it could reverse only if the record compelled the opposite conclusion. Credibility findings favored the petitioner: the IJ found both the petitioner and his expert credible. But credibility alone does not carry the day when the record, taken as a whole, permits the IJ/BIA to conclude that key probabilities (here, knowledge and location) have not crossed the “more likely than not” threshold. The panel’s analysis is classic substantial-evidence review: it did not re-weigh evidence but asked whether a reasonable adjudicator could reach the same conclusion; finding that to be true, it affirmed.

Impact and Practical Implications

Although nonprecedential, this order will be influential in how IJs, the BIA, and practitioners structure and evaluate CAT claims premised on retaliation by transnational criminal organizations:

Structuring proof: For theories that depend on multiple contingencies (e.g., discovery of cooperation, decision to retaliate, ability to locate, state acquiescence), adjudicators may organize analysis into discrete links and require each to be “more likely than not.” Petitioners should present specific, non-speculative evidence on every link.
Knowledge of cooperation: Evidence that persecutors can access publicly available details, leaks, or patterns that reliably reveal cooperation is crucial. Sealed dockets, lack of public testimony, and mere curiosity about release dates will weigh against finding that persecutors are more likely than not to discover cooperation.
Ability to locate and internal relocation: General country-conditions evidence that a cartel operates nationwide may be insufficient. Applicants should address whether the organization can specifically find them—e.g., personal identifiers, network reach to their anticipated region, prior tracking behavior, or the absence of any safe region for relocation. The regulation expressly makes internal relocation a factor for CAT.
Debt enforcement versus torture: Where debt-based coercion is alleged, the record should distinguish ordinary criminal coercion or forced labor from conduct that rises to “torture” (severe pain or suffering). Evidence of routine use of extreme violence, severe physical abuse, or analogous acts in the country of removal specifically in debt-collection contexts may be necessary to meet the CAT definition.
Acquiescence: Even where government infiltration exists, petitioners will benefit from tying that infiltration to specific, reliable failures to prevent or respond to torture in the region of intended relocation, consistent with the “willful blindness”/consent standard for official acquiescence (though the court did not reach this link here).
Harmless/dispositive-issue approach: Appellate bodies may decline to address additional issues once one or more dispositive links fail, reinforcing the need to make each link independently robust in the record.

Complex Concepts Simplified

“More likely than not”: In CAT claims, applicants must show a greater than 50% chance of being tortured if removed to the country in question.
Substantial evidence review: A deferential standard on petition-for-review; the court of appeals asks only whether the agency’s decision is supported by reasonable, probative evidence in the record. It reverses only if the evidence compels a contrary finding.
CAT deferral vs. withholding: CAT “deferral of removal” is available even to certain noncitizens barred from other forms of relief (e.g., aggravated felons). It offers protection from removal to a specific country but is more easily revisited/terminated than CAT withholding.
Acquiescence of a public official: Under U.S. regulations implementing CAT, torture must occur with the consent or acquiescence (including willful blindness) of a public official acting under color of law.
Internal relocation as a CAT factor: While CAT does not impose a formal “reasonableness of relocation” requirement as in asylum, adjudicators must consider whether the applicant could avoid torture by relocating within the country of removal. If safe areas exist where torture is unlikely, that weighs against CAT relief.
Nonprecedential disposition: This order is designated “nonprecedential” and may be cited only in accordance with Federal Rule of Appellate Procedure 32.1. It is not binding precedent in the Seventh Circuit but can be persuasive.

Conclusion

C.N.T. v. Bondi reinforces, albeit in a nonprecedential order, a rigorous, link-by-link approach to CAT proof when the feared harm depends on a chain of contingent events. The Seventh Circuit held that substantial evidence supported the IJ/BIA’s conclusion that two essential links—the cartel’s likely discovery of cooperation and its likely ability to locate the petitioner in Guatemala—were not established to the requisite “more likely than not” standard. Because those links failed, the court was not required to reach cartel intent or official acquiescence. The panel also endorsed the view that debt-based forced labor, without additional evidence of severe pain or suffering, does not amount to torture under CAT.

Key takeaways:

CAT applicants must present specific, non-speculative evidence for each necessary link in any causal chain leading to torture.
Sealed criminal proceedings and lack of public cooperation evidence may undercut the “knowledge” link in cooperator-risk cases.
Evidence of nationwide cartel presence is not a substitute for proof that the organization can actually locate the applicant anywhere in the country of removal; internal relocation remains a relevant factor.
Debt enforcement alone does not equal “torture”; additional evidence of severe pain or suffering is needed.
Appellate courts may affirm on dispositive gaps without addressing all remaining issues.

For practitioners, the opinion underscores the importance of building a record that speaks directly and concretely to each link—how the persecutor will learn of cooperation, why it will decide to torture, how it will find the applicant despite relocation, and how state actors will consent or acquiesce—while distinguishing ordinary criminal coercion or forced labor from conduct that meets the stringent CAT definition of torture.