The Eighth Circuit has rejected family-based withholding of removal claim. Extortionists had killed the petitioner’s stepfather after he was unable to pay extortion. They then threatened to kill petitioner’s mother and siblings. However, the court found this threat to be insufficient to demonstrate that any harm the petitioner would suffer would be on account of her family membership, as opposed to the extortionists’ desire to obtain money.
The full text of Silvestre-Giron v. Barr can be found here:
https://ecf.ca8.uscourts.gov/opndir/20/02/182887P.pdf