Seven years after holding that “wealthy landowners” may be a particular social group, the Ninth Circuit has now rejected an asylum claim by the same petitioner. Noting that intervening case law required an asylum applicant to demonstrate that the society in question perceived the proposed group as a group, the court held that the record did not establish that Colombian society perceives wealth landowners as a group. This case is a good reminder of the importance of building a record of societal perception into the record.
The full text of Cordoba v. Barr can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/06/16/17-71655.pdf