The Tenth Circuit, while assuming that family could be a valid particular social group, rejected an asylum claim where the “gang was threatening family members as a means to achieve an end that was unrelated to a protected ground.” The court recognized its decision was contrary to Fourth Circuit precedent involving a similar fact pattern.

The full text of Orellana Recinas v. Garland can be found here:
https://www.ca10.uscourts.gov/opinions/19/19-9596.pdf

Comment