Sales Ramirez: Country Evidence, Nexus and Government Protection

Credibility, country conditions and proof of the legal elements remained separate questions in Sales Ramirez v. Bondi. In its January 7, 2026 memorandum, the Ninth Circuit denied review of an asylum and withholding decision after examining the record on nexus, government protection and the fairness of the hearing. The court did not hold that country reports are irrelevant or that the applicant had been found generally untruthful.

Sales Ramirez v. Bondi, No. 25-196 (9th Cir. Jan. 7, 2026), is nonprecedential except as Ninth Circuit Rule 36-3 permits.

The petition and the scope of review

Lizandra Josefina Sales Ramirez and her minor daughter, natives of Guatemala, sought review of the Board’s affirmance of the immigration judge’s denial of asylum and withholding. The daughter was a derivative asylum applicant and had not filed an independent application. The court’s references to the principal petitioner therefore concerned the mother. See pages 1–2 and footnote 1.

The panel considered three groups of arguments: Nexus between the harm and a protected ground, whether the government was unable or unwilling to protect her, and alleged due process defects. Other arguments were waived or unexhausted. When the Board adopted the immigration judge’s reasoning and added its own, the court reviewed both the Board decision and the adopted portions of the judge’s decision. Legal and due process questions received de novo review; factual findings received substantial-evidence review.

General vulnerability did not compel a motive finding

Sales Ramirez argued that she was assaulted because of her Indigenous ethnicity or membership in groups identified as Indigenous Guatemalan women and Mam women. She relied substantially on general country-conditions evidence. The panel concluded that the record did not compel a finding that her attackers selected her because of those protected traits rather than a general criminal motive. See pages 2–3.

The court also concluded that the general country evidence did not supply the missing individualized connection on this record. That is a substantial-evidence holding, not a declaration that context cannot help prove motive. Because the protected-ground connection for past persecution was not established, the associated argument for a presumption of future persecution failed as well. See page 3, footnote 3.

The statistic carried its own limitations

On government protection, the petitioner emphasized an article suggesting that a very small proportion of complaints about violence against women resulted in a punitive sentence. The panel pointed out that the article itself described limitations making its underlying data outdated and inconsistent. It held that the record did not compel reversal of the agency’s finding that she failed to establish the authorities were or would be unable or unwilling to protect her. See pages 3–4.

The distinction matters. The decision did not impose a numerical conviction-rate test or treat every statistical source as defective. It evaluated the evidence offered in this particular record, including a limitation stated by the source on which the petitioner relied.

The due process claims did not establish a denied opportunity

The petitioner argued that the judge failed to consider evidence supporting her nexus theory. The court identified the materials the judge actually considered: A psychological evaluation, an expert report on Guatemala and the 2021 State Department Human Rights Report. She had not identified testimony she was prevented from presenting or evidence that the judge overlooked. The court found no due process violation. See pages 4–5.

She separately challenged the absence of a formal credibility determination. The panel noted that the judge found her generally credible despite several inconsistencies and that the Board therefore had to presume credibility. There was no identified due process violation on that ground. An account can be credited while the evidence still fails to establish motive or government-protection elements.

The result and the record-review lesson

The panel denied the petition. It denied the stay motions as moot and directed that the temporary stay dissolve upon issuance of the mandate. The memorandum does not by itself establish a later mandate date, removal or present custody status.

For a similar review, identify the exact element at issue, the evidence the agency acknowledged and the standard the court applied. A source’s limitations and an argument actually preserved before the Board can be as consequential as the volume of documents submitted. Our paired country-report statistics guide offers a practical source-audit method. The immigration defense page explains the broader representation pathway.