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Urias-Orellana v. Bondi · ¶12

The IJ credited Urias-Orellana's account of the facts but concluded that those facts were insufficient to establish either past persecution or a well-founded fear of future persecution. The IJ explained that, under First Circuit precedent, death threats may establish past persecution only when they are “ `so menacing as to cause significant actual suffering or harm.' ” App. to Pet. for Cert. 31a (quoting Bonilla v. Mukasey, 539 F. 3d 72, 77 (CA1 2008)). The IJ concluded that Urias-Orellana's past-persecution claim failed under that standard, as he had not submitted any medical, psychiatric, or psychological evaluations indicating that he had experienced such suffering or harm. App. to Pet. for Cert. 31a–32a. The IJ further found the evidence regarding Urias-Orellana's alleged fear of future persecution to be lacking. He observed that Urias-Orellana had successfully escaped danger after…
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