## Facts

- Two Salvadoran citizens entered the United States without inspection and were placed in deportation proceedings.
- They conceded deportability and sought asylum and withholding of deportation, claiming fear of harm if returned to El Salvador during the civil conflict.
- They asserted membership in a proposed “particular social group”: young, urban, working-class males of military age who had not served in the Salvadoran military or supported the government.
- They contended members of this group faced violence and coercive recruitment pressures from government forces and guerrillas.
- One petitioner also claimed an individualized fear based on actual or imputed political opinion, citing several brief detentions and searches by security forces, each ending in release without charges.
- The immigration judge denied relief, finding the proposed group not cognizable and finding insufficient individualized proof of persecution; the Board of Immigration Appeals affirmed.

## Issues

1. Whether the proposed cohort of young, urban, working-class Salvadoran males of military age who had not served or supported the government qualifies as a “particular social group” under the INA’s refugee definition.
2. Whether the record compelled findings of a well-founded fear (asylum) or a clear probability (withholding) of persecution on account of actual or imputed political opinion.
3. What level of deference and evidentiary review applies to the BIA’s interpretation of “particular social group” and its factual findings on fear of persecution.

## Decision

- The court denied the petition for review and affirmed the BIA’s denial of asylum and withholding.
- The proposed “social group” was rejected as too broad, internally diverse, and amorphous to qualify as a “particular social group.”
- Substantial evidence supported the BIA’s finding that petitioners showed, at most, exposure to generalized violence and risks associated with civil conflict rather than persecution “on account of” a protected ground.
- The court upheld the rejection of the individualized political-opinion claim because the brief detentions and searches, followed by releases, did not compel a finding of political persecution or a well-founded fear.

## Legal Principles

- A “particular social group” must be sufficiently discrete and defined; broad demographic cohorts defined by generalized traits and encompassing large segments of a society are not, without more, cognizable.
- Asylum and withholding require targeted harm “on account of” a protected ground; generalized dangers of civil unrest, indiscriminate violence, or generalized recruitment pressures do not alone establish persecution under the INA.
- The BIA’s interpretation of immigration statutes receives judicial respect, and the agency’s factual findings are reviewed for substantial evidence; reversal is warranted only when the record compels a contrary conclusion.
- For political-opinion claims, episodic questioning or brief detentions in a volatile environment, without particularized evidence of targeting for political beliefs (actual or imputed), may be insufficient to establish the required fear or probability of persecution.

## Conclusion

The Ninth Circuit upheld the denial of asylum and withholding because the petitioners’ proposed demographic cohort was not a cognizable “particular social group,” and the evidence supported only generalized risks from El Salvador’s civil conflict rather than persecution tied to a protected ground.


Sanchez-Trujillo v. Immigr. & Naturalization Serv., 801 F.2d 1571 (9th Cir. 1986)