The Ninth Circuit has determined that “but-for causation” is one way - but not the only way - to establish that a protected ground was one central reason for persecution. “Sometimes, a protected ground will be a but-for cause of the harm and play more than a minor role, but it won’t be sufficient on its own to cause the harm. Other times, a protected ground will be sufficient on its own, but it won’t be a but-for cause because there is another unprotected ground that would be sufficient on its own. Under Parussimova, both circumstances meet our ‘one central reason’ standard.” Employing this analysis, the Court concluded that an applicant’s Jehovah’s Witness faith was one central reason for the harm he experienced when gang members threatened to harm him if he did not stop preaching, even while they also extorted money from him.
The full text of Alfaro Manzano v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/06/25/22-704.pdf