(United States Ninth Circuit) - In a petition for review of the Board of Immigration Appeals (BIA) decision affirming the denial of withholding of removal and protection under the conference Against Torture,the petition is: 1) denied in portion where the BIA reasonably determined that petitioner's proposed particular social group of 'former members of Mara 18 gang' lacks particularity and social distinction, and that his proposed social group of 'deportees from the United States to El Salvador' lacks particularity; and 2) granted in portion where the BIA applied an impermissible standard of review in assessing the request for CAT relief.
Source: findlaw.com