Case Summary:

Urias-Orellana v. Bondi involves Douglas Humberto Urias‑Orellana, his wife, and their child, Salvadoran nationals who entered the United States without authorization in 2021 and conceded removability but applied for asylum and Convention Against Torture protection based on escalating threats and one physical assault tied to gang extortion in El Salvador. An immigration judge found Urias‑Orellana credible but concluded that the threats and single non‑hospitalizing assault, combined with his ability to relocate within El Salvador for periods without incident, did not amount to “past persecution” or a well‑founded fear of future persecution. The Board of Immigration Appeals affirmed, and the First Circuit, treating the persecution determination as a factual question subject to deferential substantial‑evidence review, upheld the B ...