The First Circuit Court of Appeals denied a petition for review from Rosa Lidia Cante Mijangos, a Guatemalan woman seeking asylum protection after fleeing years of domestic violence, according to a decision issued February 18, 2026.

Circuit Judge Rikelman, writing for the panel that included Chief Judge Barron and Circuit Judge Kayatta, upheld the Board of Immigration Appeals' rejection of Cante Mijangos's asylum and withholding of removal claims. The court acknowledged the severity of abuse she experienced while emphasizing that the petitioner failed to properly challenge the legal and factual foundations of the immigration court's decision.

Cante Mijangos, a citizen of Guatemala, endured sexual and physical abuse from her former intimate partner Walter for multiple years. Their relationship began in 2007, but the documented abuse started in 2010 and continued until she fled to the United States in 2014, fearing for her safety. She subsequently applied for asylum and withholding of removal under federal immigration statutes.

The central legal issue in the case involved the "nexus" requirement under asylum law, which mandates that applicants demonstrate a connection between the persecution they faced and their membership in a protected group. Cante Mijangos claimed protection as a "Guatemalan woman who was unable to effectively leave a domestic relationship," seeking to establish this as a particular social group eligible for asylum protection.

However, the Immigration Judge rejected her claims after determining that Cante Mijangos had not established the required nexus between the harm she experienced and her asserted protected status. The IJ concluded instead that her former partner's abuse stemmed from "his generally violent nature" rather than her membership in the proposed social group.

This finding proved crucial to the case's outcome, as asylum law requires applicants to show that persecution was inflicted "on account of" their membership in a protected group based on race, religion, nationality, political opinion, or membership in a particular social group. The Immigration Judge's determination that the abuse was motivated by the perpetrator's violent character rather than the victim's group membership created an insurmountable legal hurdle.

The Board of Immigration Appeals subsequently affirmed the Immigration Judge's decision, agreeing with the nexus analysis and other factual determinations. The BIA's affirmation cleared the way for Cante Mijangos to petition the First Circuit for judicial review of the administrative decision.

In their brief before the appeals court, government attorneys from the U.S. Department of Justice's Office of Immigration Litigation defended the lower courts' rulings. The government team included Attorney Marie V. Robinson, Assistant Attorney General Brett A. Shumate from the Civil Division, and Assistant Director Cindy S. Ferrier.

Cante Mijangos was represented by attorney Lidia M. Sanchez, who argued that the immigration courts had improperly applied the nexus standard in evaluating her client's asylum claim.

The First Circuit's denial turned on procedural grounds rather than a substantive review of asylum law principles. Circuit Judge Rikelman emphasized that while the court "does not minimize the harm that Cante Mijangos experienced," the petitioner had "failed to develop any challenge to the legal and factual bases for the BIA's ruling."

This procedural deficiency meant that the appeals court could not conduct a meaningful review of whether the immigration courts had correctly applied asylum law to Cante Mijangos's circumstances. Federal courts of appeals generally require petitioners to present specific legal arguments challenging administrative decisions, and failure to adequately develop such challenges can result in denial regardless of the underlying merits.

The case reflects ongoing challenges facing domestic violence survivors seeking asylum protection in the United States. While immigration law recognizes that domestic violence can form the basis for asylum claims when properly connected to protected characteristics, establishing the required legal nexus remains complex and fact-intensive.

Domestic violence asylum cases often require extensive documentation of both the abuse suffered and the social, cultural, or political factors that prevented victims from obtaining protection in their home countries. Successful claims typically must demonstrate that the persecution was motivated by the victim's membership in a particular social group rather than purely personal or criminal motives.

The First Circuit's decision in *Cante Mijangos v. Bondi* demonstrates the critical importance of developing comprehensive legal arguments when challenging immigration court decisions on appeal. The case also highlights the procedural requirements that govern federal court review of administrative immigration decisions.

For immigration practitioners, the decision serves as a reminder that appellate advocacy must address both the substantive legal standards governing asylum claims and the specific factual determinations made by immigration judges and the BIA. Failure to adequately challenge either component can result in denial of review regardless of the strength of the underlying asylum claim.

The denial leaves Cante Mijangos subject to the original removal order, though she may still have other potential avenues for relief depending on her specific circumstances and changes in immigration policy or law.