The Fifth Circuit has remanded an asylum claim involving fear of gangs because the Immigration Judge erroneously required the petitioner to demonstrate past persecution in order to establish a well-founded fear of future persecution and because the Immigration Judge failed to analyze the cognizability of the particular social group put forth by the petitioner, instead evaluating (and rejecting) a social group of his own formulation.
The full text of Cabrera v. Sessions can be found here:
http://www.ca5.uscourts.gov/opinions/pub/15/15-60711-CV0.pdf