The Supreme Court of the United States unanimously ruled in favor of the federal government in Urias-Orellana v. Bondi, clarifying how appellate courts must review asylum decisions. Writing for the court, Ketanji Brown Jackson said federal courts of appeals must apply a deferential āsubstantial evidenceā standard when evaluating whether asylum applicants have demonstrated persecution.
The case involved Douglas Humberto Urias-Orellana, his wife Sayra Iliana Gamez-Mejia, and their child, who fled El Salvador in 2021 seeking asylum in the United States. Urias-Orellana claimed a hitman had targeted his family and had already killed two of his half-brothers. He also said individuals linked to the assailant repeatedly demanded money and attacked him once.
Under the Immigration and Nationality Act, asylum applicants must show persecution or a well-founded fear of persecution based on factors such as race, religion, nationality, political opinion, or membership in a particular social group. An immigration judge determined that Urias-Orellanaās experiences did not meet that threshold, noting the family had previously relocated within El Salvador to avoid danger. The Board of Immigration Appeals upheld the decision in 2023. In its ruling, the Supreme Court said appellate courts must defer to agency findings unless the evidence compels a different conclusion. Jackson wrote that Congress effectively codified this approach after the courtās earlier decision in INS v. EliasāZacarias (1992), reinforcing that agency determinations should stand unless clearly contradicted by the record.
