The Ninth Circuit has determined that an unrepresented litigant sufficiently alerted the Board of Immigration Appeals to the issues on appeal. Petitioner wrote that “the police from my government of Honduras didn’t do nothing to help me.” That statement put the BIA on notice that Petitioner believed the IJ was incorrect in concluding that she had failed to meet her burden of demonstrating that the police would be unable or unwilling to protect her. Additionally, Petitioner wrote that ‘the gangs MS-13 there in all the places in Honduras.’ In context, that statement notified the BIA that Petitioner disputed the IJ’s conclusion that she could relocate safely within Honduras.”
The full text of Nolasco-Amaya v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/09/28/20-70187.pdf