The Ninth Circuit has rejected the proposed particular social groups of “Salvadoran women who refuse to be girlfriends of MS gang members” and “Salvadoran women who refuse to be victims of violent sexual predation of gang members,” finding that the groups lacked social distinction. The court acknowledged that the record evidence establishes “generally that women in El Salvador can be ill-treated.”
The full text of Villegas Sanchez v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/03/11/16-73745.pdf