Salinas Luna: Threat Details and an Unchallenged Relocation Finding Sustained Denial

Threats against a parent and children can make a family fear returning home. An immigration appeal still turns on the particular evidence and every independent reason the agency gave for denying protection. In Salinas Luna v. Blanche, No. 24-5929 (9th Cir. Oct. 30, 2026), the Ninth Circuit denied the petition after reviewing the threat accounts and other evidence. The family’s failure to challenge a separate internal-relocation finding was independently decisive, as the discussion beginning on the third page explains.

The written account and hearing testimony described the threat differently

Carolina Salinas Luna and her sons sought asylum, withholding of removal and protection under the Convention Against Torture. The Board of Immigration Appeals affirmed without an opinion, so the court reviewed the immigration judge’s decision as the final agency determination. Factual findings were reviewed for substantial evidence: The question was whether the evidence required a contrary conclusion.

The applicant argued that she had received death threats. The memorandum’s first footnote identifies an important difference. Her application described an explicit death threat during an encounter with armed men. When asked at the hearing to supply the details, she described a threat to harm her and her children and did not mention a death threat. That account appears in Salinas Luna. The court’s analysis focused on what the testimony and surrounding events established.

The court also examined the surrounding incidents. Two masked, unarmed men demanded money at the store, threatened harm if she did not pay and left after about 30 minutes without injuring anyone or taking money. They were not seen again. In another incident, two unknown men approached her and her children on the street and demanded money, but did not carry out the alleged threat. Those details appear in Salinas Luna.

The surrounding facts supported the agency’s assessment of past harm

The court recognized that a death threat can constitute persecution. It nevertheless found that this record did not compel a finding of explicit threats to the family’s lives. It also considered the alternative even if such threats had occurred: Their vague and anonymous character, absence of accompanying violence and lack of follow-through supported the agency’s conclusion on this record. The reasoning begins in Salinas Luna and continues on the next page.

That is a factual comparison, not an instruction to wait for an attack or a word-choice test in which saying “death” establishes eligibility. The applicant’s exact account, the perpetrators’ conduct and the surrounding evidence all informed the court’s review. Our guide to threat evidence discusses the broader evidentiary question.

The relocation ruling required its own challenge

The immigration judge separately found that the family could reasonably relocate within Mexico. The applicant said she lacked friends elsewhere and believed the men would follow her, but gave no explanation supporting that belief. Her petition argued that future fear was objectively reasonable without disputing the relocation finding. The court treated that unchallenged finding as independently dispositive. Its discussion begins in Salinas Luna and continues on the next page.

This part of the reasoning explains why improving one argument may not resolve an appeal. A challenge to the severity of past threats and a challenge to a separate relocation finding address different grounds. The decision illustrates the importance of reading the actual reasons in the agency order and addressing each material one through the proper process.

Withholding and CAT required separate attention

The applicant argued that the judge had failed to apply withholding’s lower “a reason” motive standard. The court quoted the judge’s assumption that a protected ground could be a reason for harm, followed by the distinct finding that future harm had not been shown more likely than not. It rejected the withholding challenge on that likelihood analysis. The court’s treatment appears in Salinas Luna; it does not establish a finding that a particular proposed ground was proved.

For CAT, the court found generalized descriptions of violence insufficient to compel a conclusion that this applicant was likely to be tortured. It also addressed the required government involvement or acquiescence. There was no evidence connecting the men to the government or showing government participation. Calls to police about outbreaks of violence in the hometown, followed by no police appearance, were insufficient on this record. That discussion begins in Salinas Luna and continues on the fifth page, where the petition is denied.

A useful review connects the original words to the complete decision

Keep separate the words used by the threatening person, a translation, an applicant’s description of their meaning and the legal characterization of the harm. Our guide to comparing a declaration with hearing testimony develops that task. The full application, transcript and agency order are needed to assess a difference honestly and to identify separate findings that also require attention. The memorandum resolves this family’s petition on its record; another person’s evidence needs its own review.