In an unpublished decision, the Ninth Circuit remanded a case in which the petitioner asserted that she was persecuted on account of her membership in the group comprised of "young women who have been solicited by gangs." The petitioner was initially approached by four members of the Mara Salvatrucha gang who asked her to join. She then faced a series of threatening or violent encounters with some of the same gang members, and was persecuted every week by the gangs. The Ninth Circuit concluded that this evidence compelled the conclusion that she was persecuted on account of her membership in the proposed social group. As such, the Court remanded the case, to allow the agency to determined if the proposed social group met the revised social distinction and particularity requirements articulated by the Board of Immigration Appeals in Matter of W-G-R- and Matter of M-E-V-G-. In so doing, the Court noted that it had previously determined that "persons taking concrete steps to oppose gang membership and gang authority” may be a cognizable social group, citing its decision in Pirir-Boc v. Holder.
The full text of Orellana-Lara v. Lynch can be found here: https://cdn.ca9.uscourts.gov/datastore/memoranda/2016/03/28/12-73221.pdf
