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Third Circuit Denies Guatemalan's Asylum Appeal in Immigration Case

The Third Circuit Court of Appeals denied Huber Adelmar Camaja-Ceballos's petition for review of a Board of Immigration Appeals removal order. The court upheld the BIA's denial of his applications for asylum, withholding of removal, and relief under the Convention Against Torture.

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4 min readcourtlistener
Seal of the Third Circuit Court of Appeals

Case Information

Case No.:
No. 25-1515

Key Takeaways

  • Third Circuit denied Guatemalan national's asylum petition for review
  • Petitioner claimed persecution by gang members but provided inconsistent testimony
  • Court upheld BIA's denial of asylum, withholding of removal, and CAT relief

The Third Circuit Court of Appeals denied a Guatemalan national's petition for review of an immigration removal order, upholding the Board of Immigration Appeals' rejection of his asylum claims. In *Huber Adelmar Camaja-Ceballos v. Attorney General United States of America*, the court issued a non-precedential opinion on Jan. 20, 2026, affirming the BIA's final order of removal.

Camaja-Ceballos, who unlawfully entered the United States in 2018, faced removal proceedings initiated by the Department of Homeland Security in 2020. The petitioner conceded his removability but sought protection through multiple avenues: asylum, withholding of removal, and relief under the Convention Against Torture.

The case presents a complex immigration narrative involving claims of persecution in Guatemala. According to court documents, Camaja-Ceballos initially claimed in his declaration that he was targeted by unidentified gang members who sought to recruit him and commit robbery against him. However, his testimony evolved during the hearing process, where he claimed persecution based on his religion and membership in a particular social group.

The factual foundation of his asylum claim centers on events that allegedly occurred when Camaja-Ceballos was 14 years old. In his declaration, he described threats from two gang members, though the complete details of these incidents were not fully elaborated in the available court documents.

Immigration Judge Mirlande Tadal initially heard the case before it proceeded to the Board of Immigration Appeals. The BIA's denial of Camaja-Ceballos's applications prompted the petition for review to the Third Circuit, where the case was submitted under Third Circuit Local Appellate Rule 34.1(a) on Nov. 14, 2025.

The three-judge panel consisted of Circuit Judges Shwartz, Matey, and Montgomery-Reeves, with Judge Montgomery-Reeves authoring the opinion. The court's decision represents a standard immigration appeal where the petitioner challenged the administrative findings regarding his eligibility for various forms of relief from removal.

Asylum law requires applicants to demonstrate persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion. The statute also requires that applications be filed within one year of arrival, subject to certain exceptions. Withholding of removal provides protection for individuals who can show a clear probability of persecution, while Convention Against Torture relief protects those likely to be tortured if returned to their home country.

The case illustrates common challenges in immigration proceedings, where applicants must present coherent and credible testimony about past persecution or future threats. Inconsistencies between written declarations and oral testimony can undermine credibility determinations, which are typically given significant deference by reviewing courts.

Federal courts of appeals review BIA decisions under established standards that generally defer to administrative fact-finding while reviewing legal questions de novo. The substantial evidence standard applies to factual determinations, meaning the BIA's findings will be upheld if supported by reasonable, substantial, and probative evidence in the record.

The Third Circuit's denial of the petition means Camaja-Ceballos exhausted his appeals within the federal court system. The non-precedential nature of the opinion indicates it will not serve as binding authority for future cases, though it may provide persuasive guidance in similar factual circumstances.

Immigration practitioners note that successful asylum claims typically require detailed, consistent testimony supported by country condition evidence and expert testimony when appropriate. Cases involving gang violence in Central America have faced particular scrutiny following various administrative and judicial decisions that have narrowed the scope of cognizable social groups and persecution theories.

The outcome reflects broader patterns in immigration adjudication, where courts carefully scrutinize claims for protection while balancing humanitarian concerns against immigration enforcement priorities. Credibility determinations remain central to asylum adjudications, with immigration judges and the BIA evaluating factors including consistency, plausibility, and demeanor.

For Camaja-Ceballos, the denial likely means he faces removal to Guatemala unless other relief becomes available. The case was assigned alien number A216-544-889 for administrative tracking purposes.

The decision underscores the complexity of immigration law and the high evidentiary standards required for successful asylum claims. While each case turns on its specific facts and circumstances, the outcome demonstrates the challenging legal landscape facing individuals seeking protection from persecution in their home countries.

Topics

asylumwithholding of removalConvention Against Torturegang violencepersecutionimmigration appeals

Original Source: courtlistener

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