I. Introduction

In Oliva‑Oliva v. Bondi, No. 25‑9511 (10th Cir. Nov. 25, 2025), the United States Court of Appeals for the Tenth Circuit denied a Guatemalan father's petition for review of the Board of Immigration Appeals’ (BIA) denial of asylum and withholding of removal. The case presents a recurring issue in contemporary asylum litigation: whether threats and violence arising from common criminal activity—here, an attempted motorcycle theft and subsequent death threats—are sufficiently connected (“nexus”) to a protected ground to qualify as persecution “on account of” a particular social group.

Although the court issued an unpublished order and judgment—explicitly non‑precedential except under doctrines such as law of the case, res judicata, and collateral estoppel—the decision is highly instructive. It crystallizes and applies an important rule:

Employment or other status that merely enables a persecutor to identify, locate, or contact a victim—without itself being a motive for the harm—is only an incidental factor and does not satisfy the nexus requirement for asylum or withholding of removal.

This commentary examines the factual background, the legal framework, the court’s reasoning, the precedents it relied on, and the broader implications for asylum and withholding claims based on criminal violence and alleged incapacity of the state to protect victims.

II. Summary of the Opinion

A. Parties and Posture

Petitioners Luis Alberto Oliva‑Oliva and his minor daughter are natives and citizens of Guatemala. The daughter’s claim is entirely derivative as a rider on her father’s asylum application. They sought:

• Asylum under 8 U.S.C. § 1158, and
• Withholding of removal under 8 U.S.C. § 1231(b)(3).

The Immigration Judge (IJ) found Mr. Oliva‑Oliva credible and recognized an objectively reasonable fear of harm if returned to Guatemala, but denied relief for failure to establish:

1. Past harm rising to the level of persecution, and
2. The required nexus between feared harm and a protected ground (here, a particular social group based on past employment and inability to obtain state protection).

The BIA affirmed in a single‑member decision on the nexus ground. Mr. Oliva‑Oliva petitioned the Tenth Circuit for review, challenging only the nexus determination. The Tenth Circuit, exercising jurisdiction under 8 U.S.C. § 1252(a), denied the petition.

B. Core Holding

The Tenth Circuit held that substantial evidence supported the BIA’s conclusion that the harm Mr. Oliva‑Oliva suffered and feared was not “on account of” his proposed particular social group. Rather:

• The attempted motorcycle theft was a crime of opportunity motivated by the attackers’ desire to steal his motorcycle; and
• The subsequent threats were motivated by the attackers’ desire to silence a witness who could identify one of them to the police.

His employment at the Del Monte Company (which allowed the persecutor to know he had a motorcycle and to have his contact information) was, at most, an incidental or tangential factor. It was not “at least one central reason” for the harm, as required by 8 U.S.C. § 1158(b)(1)(B)(i).

Because he failed to satisfy nexus for asylum, he necessarily failed to meet the more stringent standard for withholding of removal.

III. Factual and Procedural Background

A. Facts Underlying the Claim

Mr. Oliva‑Oliva’s work history in Guatemala included:

• Mason
• Farmer
• Seasonal day laborer for a branch of the Del Monte Company, operating a melon‑irrigation machine.

At Del Monte, irrigation operators needed to coordinate, which meant workers had one another’s cell phone numbers. Mr. Oliva‑Oliva commuted home from work by motorcycle.

One early morning in February 2018, after an overnight shift:

• Three individuals attempted to steal his motorcycle.
• They tried to knock him off and then chased him on their own motorcycles.
• He escaped, but recognized one attacker as a co‑worker, “E.M.”

After the attempt, he refused to return to work for Del Monte. E.M., who had his number from work, called and discovered that Mr. Oliva‑Oliva had recognized him. E.M. then threatened to kill him if he reported the crime to the police. Mr. Oliva‑Oliva subsequently received multiple threatening calls from various people.

He reported the incident to Del Monte managers but received no effective assistance. He did not report to the police because he doubted they would protect him and feared that corrupt officers might instead hand him over to the attackers.

In February 2019, he left his town and moved to other departments within Guatemala. In July 2019, he left Guatemala for the United States, where he applied for asylum and withholding of removal. He also sought Convention Against Torture (CAT) relief before the IJ, but he did not seek review of the CAT denial in the Tenth Circuit.

B. The Claimed Particular Social Group

Mr. Oliva‑Oliva advanced a particular social group (PSG) defined as:

“Guatemalans who experience extortion or threats of violence based on their past employment and their inability to obtain state protection.”

Importantly, the IJ and the BIA decided the case on nexus grounds and did not definitively rule on the legal cognizability of this PSG (i.e., whether it meets the immutability, particularity, and social distinction requirements). The Tenth Circuit similarly assumed the group arguendo and focused exclusively on whether the harm was “on account of” that group.

C. Agency Decisions

1. Immigration Judge

The IJ found:

• Credibility: Mr. Oliva‑Oliva testified credibly, with adequate corroboration.
• Objective fear: There was an objectively reasonable fear of harm if he returned to Guatemala.
• No past persecution: The past harm—consisting largely of threats—did not rise to the level of “persecution,” noting the principle in Vatulev v. Ashcroft that threats alone “generally do not constitute actual persecution.”
• No nexus: The critical determination was that there was no nexus between the feared harm and the proposed PSG.

The IJ described the incident as a “crime of opportunity”:

“[T]he record taken as a whole does not show that his past employment for the Del Monte corporation is a significant motivating factor for any harm he was threatened with. This was a crime of opportunity, in that [E.M.] and the persons who assisted him apparently were aware that respondent had a motorcycle because he worked at that same Del Monte facility as [E.M.].”

The IJ emphasized that:

• The attackers’ awareness of his motorcycle and access to his contact information came through ordinary work interaction.
• There was nothing suggesting they acted to punish him or to overcome a characteristic linked to his employment as a melon irrigator.

The IJ concluded:

“[T]o the extent [his] employment at Del Monte has anything to do with the case, that is only as an incidental or a tangential factor. But it is not a central reason for the harm he suffered or fears.”

On this basis, the IJ denied asylum and, by consequence, withholding of removal.

2. Board of Immigration Appeals

The BIA, in a single‑member decision, affirmed the IJ. It conducted a clear‑error review of the IJ’s factual nexus finding and agreed that the evidence did not show that any harm was motivated by his employment, stating:

“The fact that [E.M.] may have learned that the respondent had a motorcycle and obtained the respondent’s contact information by virtue of their shared employment does not establish that any harm was motivated by the respondent’s employment.”

The BIA held that, because there was no nexus to a protected ground, Mr. Oliva‑Oliva had not established eligibility for asylum or withholding of removal.

IV. Standards of Review and Legal Framework

A. Court’s Scope of Review

Because the BIA issued a brief, single‑member affirmance, the Tenth Circuit:

• Primarily reviewed the BIA’s decision; but
• Consulted the IJ’s more detailed reasoning to understand the grounds adopted by the BIA, consistent with Uanreroro v. Gonzales, 443 F.3d 1197 (10th Cir. 2006).

B. Applicable Standards

• Legal questions (e.g., interpretation of statutes): reviewed de novo.
• Findings of fact (including nexus): reviewed under the substantial evidence standard, as articulated in 8 U.S.C. § 1252(b)(4)(B) and applied in Ting Xue v. Lynch, 846 F.3d 1099 (10th Cir. 2017).

Under this deferential standard, “administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.”

Critically, in line with Miguel‑Pena v. Garland, 94 F.4th 1145 (10th Cir.), cert. denied, 145 S. Ct. 545 (2024), the Tenth Circuit treats nexus—whether the persecution is “on account of” a protected ground—as a factual determination, not a purely legal one, and thus subject to substantial‑evidence review.

C. Substantive Asylum and Withholding Framework

The court recited the statutory asylum framework:

• To be eligible for asylum, an applicant must meet the definition of “refugee” in 8 U.S.C. § 1101(a)(42), as incorporated into § 1158(b)(1)(A)–(B)(i).
• A “refugee” is a person unable or unwilling to return to his country of nationality “because of persecution or a well‑founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.”
• These five categories are the “protected grounds.” (citing Rodas‑Orellana v. Holder, 780 F.3d 982, 986 (10th Cir. 2015)).

Two key points:

1. The applicant must prove persecution or well‑founded fear of persecution; and
2. The persecution must be because of (i.e., have a nexus to) a protected ground.

For withholding of removal under 8 U.S.C. § 1231(b)(3), the applicant must demonstrate a clear probability of persecution on account of a protected ground—a higher standard than the “well‑founded fear” standard for asylum. As the court reiterated from Rodas‑Orellana, “Failure to meet the burden of proof for an asylum claim necessarily forecloses meeting the burden for a withholding claim.”

V. Precedents Cited and Their Influence

A. Rodas‑Orellana v. Holder, 780 F.3d 982 (10th Cir. 2015)

Rodas‑Orellana is a foundational Tenth Circuit case on:

• The structure of asylum and withholding standards; and
• The requirement of a nexus to a protected ground, particularly in the context of gang‑related violence and claimed social groups such as “former gang members.”

The court in Oliva‑Oliva cites it for two main propositions:

1. Definition of protected grounds; and
2. The more stringent standard for withholding of removal and its dependency on satisfying asylum’s lesser burden first.

This reinforces the doctrinal structure: if nexus fails for asylum, withholding necessarily fails too.

B. Miguel‑Pena v. Garland, 94 F.4th 1145 (10th Cir.), cert. denied, 145 S. Ct. 545 (2024)

Miguel‑Pena is central to the Tenth Circuit’s recent nexus jurisprudence, especially in gang and extortion contexts. It clarified that:

• The protected ground must be “at least one central reason” for the persecution (quoting 8 U.S.C. § 1158(b)(1)(B)(i)).
• Reasons that are “incidental, tangential, superficial, or subordinate” to other motives do not suffice.
• There is “no nexus when there is no evidence that the gang would be hostile toward the targeted individuals absent their financial or recruitment motives.”

In Oliva‑Oliva, the court explicitly relies on this framework. The evidence showed that:

• The attackers’ primary motive was financial (to steal the motorcycle); and
• Later, their motive was to avoid being reported to the authorities (silencing a witness).

There was no evidence they would be hostile to him as a member of his proposed group, absent those financial and self‑protective motives. Thus, Miguel‑Pena squarely supports the conclusion of no nexus.

C. Vatulev v. Ashcroft, 354 F.3d 1207 (10th Cir. 2003)

Vatulev is cited for two related principles:

• “Threats alone generally do not constitute actual persecution,” emphasizing that not every serious threat reaches the statutory threshold of persecution.
• “Acts of common criminality or personal hostility…do not implicate asylum eligibility,” highlighting the divide between ordinary crime and persecution on protected grounds.

Although the Tenth Circuit in Oliva‑Oliva did not need to definitively resolve the “persecution” question (because nexus was dispositive), the IJ’s reliance on Vatulev underlines the broader point that even credible and serious threats can fail to amount to persecution when they stem from personal or economic motives, rather than from animus linked to a protected ground.

D. Orellana‑Recinos v. Garland, 993 F.3d 851 (10th Cir. 2021)

The Tenth Circuit in Orellana‑Recinos clarified an important nuance in the nexus analysis:

“[T]he BIA has made clear that membership in a particular social group should not be considered a motive for persecution if the persecutors are simply pursuing their distinct objectives and a victim’s membership in the group is relevant only as a means to an end—that is, the membership enables the persecutors to effectuate their objectives.” (emphasis in original).

Oliva‑Oliva is a textbook application of this principle. The attackers’ objective was to:

• Obtain the motorcycle (economic objective); and later
• Prevent reporting to authorities (self‑protection objective).

His employment at Del Monte simply:

• Enabled them to know he had a motorcycle; and
• Provided access to his phone number and thus allowed ongoing threats.

Under Orellana‑Recinos, such a connection—where group membership is merely a conduit to achieve a non‑protected objective—does not establish persecution “on account of” group membership.

E. Ting Xue v. Lynch, 846 F.3d 1099 (10th Cir. 2017)

Ting Xue is cited for the standard of review:

“‘The administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.’” (quoting 8 U.S.C. § 1252(b)(4)(B)).

This provides the legal foundation for the substantial‑evidence deference that shapes the outcome: even if another adjudicator might have viewed the evidence differently, the Tenth Circuit will not overturn the BIA unless the record compels the opposite conclusion.

F. Uanreroro v. Gonzales, 443 F.3d 1197 (10th Cir. 2006)

Uanreroro is cited for the proposition that where the BIA issues a brief decision, courts of appeals:

• Review the BIA’s decision; but
• May consult the IJ’s more complete explanation to understand the BIA’s reasoning.

This is relevant methodologically: the Tenth Circuit looks to the IJ’s detailed explanation of why employment was only incidental to the harm in order to interpret and support the BIA’s succinct affirmance.

VI. The Court’s Legal Reasoning

A. Framing the Issue: Nexus as the Only Question on Review

Before the Tenth Circuit, Mr. Oliva‑Oliva challenged only the nexus determination. He did not dispute:

• The credibility findings;
• The IJ’s conclusion that past harm did not rise to “persecution” (though the court did not need to revisit it); or
• The standards for asylum or withholding generally.

The sole question was whether substantial evidence supported the BIA’s finding that he failed to establish that the harms suffered and feared were “on account of” his proposed PSG.

B. The Petitioner’s “But‑For” Argument

Mr. Oliva‑Oliva argued:

“[B]ut for [his] employment with Del Monte, he would not have been targeted and persecuted.”

His theory was that:

• He was identified as a target because E.M. knew, through work, that he had a motorcycle; and
• E.M. had his cell phone number because of their shared employment.

Thus, in his view, his employment and inability to obtain state protection were central reasons for his targeting and threats.

The Tenth Circuit, however, implicitly rejected the sufficiency of a “but‑for” causal connection. The statutory standard—“at least one central reason”—is more demanding. A cause may be factually necessary (in a “but‑for” sense) without being a central reason for the persecutor’s actions. Employment may create opportunity without being the motive.

C. The Petitioner’s Own Testimony on Motive

The court placed substantial weight on Mr. Oliva‑Oliva’s own statements about motive. He testified, among other things:

• There was an “uprising” of motorcycle thefts between 2016 and 2018, driven by “greater demand” for stolen motorcycles.
• He attributed the motive of the thieves to poverty and the desire for “the easy way out.”
• Criminals were stealing motorcycles widely, including from people unaffiliated with Del Monte, such as independent farmers.

Most significantly, when asked if he believed he was targeted because he worked at Del Monte, he said (emphasis added by the court):

“I don’t know. What I do know [is] that it was because of a desire to steal my motorcycle. And later I found out that this gang had spread out…to several departments. I don’t think that it was because I had been working at the company. Just to steal my motorcycle.”

He also testified that once he began receiving threats, “it wasn’t just about the motorcycle anymore. Rather, silence so they wouldn’t be in any danger.” This supports the view that the threats were motivated by a desire to prevent reporting to the authorities, not by his employment status.

These admissions are pivotal. They directly undercut any claim that his Del Monte employment was a central reason for the attackers’ conduct; rather, it confirms that:

• The initial motive was economic (stealing the motorcycle).
• The later motive was to avoid criminal exposure (silencing a witness).

D. Characterizing the Harm: Crime of Opportunity and Witness Silencing

Both the IJ and the Tenth Circuit characterized the situation as:

• A crime of opportunity: The fact that E.M. and his accomplices knew he had a motorcycle and had his phone number resulted from their shared employment, but the target was the motorcycle, not the employment identity itself.
• Witness silencing: Once Mr. Oliva‑Oliva recognized E.M. and could potentially report him to the police, the threats were aimed at protecting the perpetrators from law enforcement.

The court concluded that his employment was only a means by which:

• The attackers knew he had a desirable asset; and
• They could reach him to issue threats.

Under the framework of Miguel‑Pena and Orellana‑Recinos, this does not establish that the harm occurred because of his membership in a particular social group.

E. Employment as Incidental or Tangential

The IJ’s conclusion, adopted by the BIA and endorsed by the Tenth Circuit, is encapsulated in the finding that:

“To the extent [his] employment at Del Monte has anything to do with the case, that is only as an incidental or a tangential factor. But it is not a central reason for the harm he suffered or fears.”

The Tenth Circuit found substantial evidence supported this characterization. That phrase—“incidental or tangential”—is drawn directly from statutory and case law requiring that a protected ground cannot be “incidental, tangential, superficial, or subordinate” to another reason for harm.

Practically speaking, this means:

• Even if a persecutor exploits a person’s employment connection to identify or access that person, this does not satisfy nexus if the persecutor’s true motive is non‑protected (e.g., theft, ransom, revenge, or witness intimidation).
• The employment‑linked PSG must be the reason the persecutor cares about the victim, not merely how the persecutor encounters the victim.

F. Application of the Substantial‑Evidence Standard

Applying the substantial‑evidence standard, the Tenth Circuit concluded that Mr. Oliva‑Oliva had not shown that “any reasonable adjudicator would be compelled to conclude to the contrary,” as required by 8 U.S.C. § 1252(b)(4)(B).

The record contained plausible support for the view that:

• The attackers’ motives were purely economic and self‑protective; and
• The employment connection was merely the channel through which they learned of and could threaten him.

Under this deferential review, the existence of some contrary inferences is not enough; the evidence must compel a different finding. Given the petitioner’s own testimony about motive, the evidence did not compel a finding that his PSG membership was a central reason for the attacks or threats.

G. Withholding of Removal

Having found no nexus sufficient for asylum, the court summarily held that the withholding claim necessarily failed under Rodas‑Orellana. If the applicant cannot show that persecution is “on account of” a protected ground under the lower asylum standard, he cannot meet the higher “clear probability” standard for withholding.

VII. Impact and Future Implications

A. Reinforcement of the Crime‑Versus‑Persecution Divide

Oliva‑Oliva reinforces a consistent line of Tenth Circuit authority distinguishing between:

• Ordinary criminal activity—even when serious, organized, and life‑threatening; and
• Persecution on account of a protected ground.

The court again underscores that generalized criminal motives—such as economic gain, property theft, and avoidance of prosecution—usually do not qualify as protected‑ground motives. Even serious threats or violence, if driven by common criminality or personal hostility, do not automatically support asylum or withholding.

B. Clarifying the Limits of Employment‑Based Social Groups

The proposed PSG—“Guatemalans who experience extortion or threats of violence based on their past employment and their inability to obtain state protection”—is representative of many modern asylum claims that attempt to combine:

• Past employment or perceived economic status; and
• State inability (or unwillingness) to protect victims of crime.

While the Tenth Circuit did not decide whether this PSG is legally cognizable, its analysis tells future litigants:

• It is not enough that the persecutor knows of the applicant, or can reach the applicant, because of employment;
• There must be evidence that the persecutor targets the applicant as a member of that employment‑based group.

Thus, claims based on employment—such as workers at particular companies, professions perceived as wealthy, or persons associated with foreign or multinational employers—must squarely address evidence of persecutors’ motives, beyond mere opportunity or access.

C. Strategic Implications for Asylum Advocates

The case carries several strategic lessons:

1. Develop evidence of persecutor motive.

   Advocates must thoroughly explore and marshal evidence showing that persecutors:

   • Express hostility toward the group as such (e.g., “We target Del Monte workers because …”);
   • Systematically target similar group members; or
   • Act out of mixed motives where the protected ground is at least one central reason, not merely a side effect of economic crime.
2. Avoid over‑reliance on “but‑for” causation.

   The fact that a victim would not have been in a particular place or known to a perpetrator but for some characteristic (e.g., employment) is not enough. The statutory “one central reason” test asks why the persecutors chose to harm the victim, not simply how they encountered the victim.

3. Prepare petitioners for motive questioning.

   Petitioners’ candid answers about why they believe they were targeted can be dispositive. In Oliva‑Oliva, the petitioner explicitly denied that he believed he was targeted because of his employment, affirmatively attributing the motive to theft and witness silencing. Counsel should:

   • Ensure petitioners understand the legal significance of motive;
   • Carefully elicit and clarify their honest perceptions; and
   • Where appropriate, explore evidence of perpetrators’ statements or patterns showing protected‑ground motivation.
4. Recognize the deference given to BIA findings.

   Under the substantial‑evidence standard, overturning a BIA nexus finding is difficult. Advocates must build a record that not only supports but compels a contrary finding, anticipating that marginal or ambiguous evidence will not suffice on petition for review.

D. Implications for Central American Crime‑Related Claims

Many asylum claims from Guatemala and neighboring countries arise from:

• Gangs or criminal organizations demanding extortion;
• Threats or violence against victims who resist or report crimes; and
• Systemic failures of law enforcement and judicial systems.

Oliva‑Oliva illustrates how U.S. courts typically analyze such situations:

• Economic or self‑protection motives (e.g., extortion, retaliation for testimony) are presumptively non‑protected.
• Generalized state inaction or inability to protect against crime, by itself, is not a protected ground; it usually goes to the state protection element, not the nexus element.
• To prevail, applicants must tie the persecution to a protected ground (e.g., family ties, political opinion, recognized PSG) with evidence that such membership is a central reason for the targeting.

E. Persuasive, Though Non‑Precedential, Authority

The Tenth Circuit labels this decision as an “order and judgment” that is:

“not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.”

Nevertheless, especially in the Tenth Circuit, immigration judges, the BIA, and litigants can cite it as persuasive authority when arguing:

• That an employment connection is incidental to persecution motivated by economic or self‑protective reasons; and
• That such incidental connections do not establish nexus under the “one central reason” test.

VIII. Complex Concepts Simplified

A. Asylum vs. Withholding of Removal

• Asylum: Discretionary relief allowing someone to remain in the U.S., work, and eventually apply for a green card, if they show a “well‑founded fear” of persecution on account of a protected ground.
• Withholding of removal: Mandatory (if eligible) but stricter form of protection that prevents removal to a country where the applicant faces a “clear probability” (more likely than not) of persecution on a protected ground. It does not confer the same benefits as asylum and is harder to obtain.

B. “Refugee” and Protected Grounds

A “refugee” is someone who cannot or will not return to their country because of past persecution or a well‑founded fear of future persecution on account of:

• Race
• Religion
• Nationality
• Membership in a particular social group (PSG)
• Political opinion

These are the protected grounds. Harm not connected to one of these cannot qualify as persecution for asylum/withholding purposes.

C. Particular Social Group (PSG)

A PSG is a group of people who share a characteristic that is:

• Immutable or fundamental to their identity (cannot or should not be changed);
• Defined with reasonable clarity (particularity); and
• Recognized in the society in question as a distinct group (social distinction).

In this case, the proposed group was “Guatemalans who experience extortion or threats of violence based on their past employment and their inability to obtain state protection.” The court did not decide whether this is a legally valid PSG, because it resolved the case on nexus grounds.

D. Nexus and “One Central Reason”

Nexus asks: Why is the persecutor harming the applicant?

Under 8 U.S.C. § 1158(b)(1)(B)(i), a protected ground must be “at least one central reason” for the persecution. This means:

• The protected ground must be a major, motivating reason—not a minor, incidental, or secondary factor.
• Persecutors can have multiple reasons (e.g., money, revenge, and political opinion). As long as a protected ground is one central reason, nexus exists.
• A cause that is merely a “background condition” enabling the crime (such as employment) may be a “but‑for” cause but not a “central reason.”

E. “Crime of Opportunity”

A “crime of opportunity” is a crime where:

• The perpetrator acts because a vulnerable target is conveniently available (e.g., an unattended vehicle, a wealthy‑looking passerby); and
• The victim is chosen for practical or opportunistic reasons, not because of who they are in terms of race, religion, PSG membership, or political opinion.

Such crimes usually do not satisfy the nexus requirement for asylum or withholding, absent evidence that a protected ground played a central role.

F. Substantial‑Evidence Standard

Under this standard:

• The court of appeals defers heavily to the immigration agency’s factual findings.
• It can overturn those findings only if the evidence in the record compels a different conclusion—i.e., no reasonable adjudicator could agree with the agency.
• If the evidence is mixed or allows for more than one reasonable view, the agency’s decision stands.

G. Non‑Precedential “Order and Judgment”

The Tenth Circuit often issues “Orders and Judgments” in immigration cases:

• They are not binding precedent across the circuit; future panels are not obligated to follow them.
• They may still be cited for their persuasive reasoning, consistent with federal and local rules.

IX. Conclusion

Oliva‑Oliva v. Bondi fits squarely into the Tenth Circuit’s evolving jurisprudence on asylum nexus, especially in the context of Central American criminal violence and extortion‑type harm. The decision underscores several key principles:

• Asylum and withholding relief require not only credible fear but also a clear link between that fear and a protected ground.
• Economic motives (theft, extortion) and self‑protective motives (silencing witnesses) generally do not constitute protected‑ground motives.
• Employment or similar characteristics that simply enable persecutors to identify, locate, or contact a victim are incidental unless shown to be a central reason for the persecution.
• Petitioners’ own accounts of why they believe they were targeted can decisively shape the nexus analysis.

Although non‑precedential, the case provides a clear, fact‑specific illustration of when employment‑related circumstances are insufficient to establish nexus. It will likely be cited by the government and by immigration adjudicators to argue that many crime‑driven harms in countries like Guatemala, however serious, reflect “acts of common criminality” rather than persecution “on account of” a protected ground.

For practitioners, the decision highlights the necessity of developing robust evidence of persecutor motives and of carefully framing particular social groups and nexus theories in a way that aligns with the demanding “one central reason” standard.