In a scathing opinion, the Seventh Circuit shot down the Board of Immigrations Appeals' decision denying Protection under the Convention Against Torture to an applicant who owed money to the Zetas cartel for drug transactions, who had previously been tortured by the Mexican police, and whose family had been tortured by the Zetas. The Court emphasized that the Convention only requires substantial grounds to believe an applicant would be tortured, which cannot be literally construed as a great than 50% probability of torture. Finally, the Court reminded the Board of Immigration Appeals that the entire government need not acquiesce in the torture (only a government official), nor do they have to do so in any "official capacity."
The full text of Rodriguez-Molinero v. Lynch can be found here: http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2015/D12-17/C:15-1860:J:Posner:aut:T:fnOp:N:1673810:S:0