The Ninth Circuit has clarified that a petitioner does not need to show that his relatives experienced persecution on the basis of their family membership in order to show that he himself might experience persecution as their relative. In this case, the petitioner expressed fear of persecution because of his family ties to members of an Autodefensora group, and the Immigration Judge found that the uncles who were members of the group had experienced persecution because of the membership in the group, not because of their family ties. The Ninth Circuit found that reasoning unpersuasive. “Thus, even assuming all of Blancas Hermosillo’s uncles were harmed only because of their Autodefensa memberships and not their familial relationships, that does not foreclose the possibility that Blancas Hermosillo will experience persecution as a relative of the Autodefensa leader and other members.”
The full text of Hermosillo v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2023/09/14/18-71220.pdf