The Ninth Circuit has determined that the Roma are a disfavored ethnic group in Romania for asylum and withholding of removal purposes. The Court also reaffirmed that shootings, attempted kidnappings, and attempted rapes are all forms of physical harm that almost always rise to the level of persecution.
The full text of Lapadat v. Bondi can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2025/02/12/23-1745.pdf