In an unpublished decision, the Ninth Circuit reminded the Board of Immigration Appeals (BIA) that when evaluating an applicant's claim under the Convention Against Torture, the BIA must consider the aggregate risk of torture from all potential sources of harm, and not evaluate the risk of harm from each source on an individualized basis.
The full text of Quintero-Molina v. Lynch can be found here:
https://cdn.ca9.uscourts.gov/datastore/memoranda/2016/12/27/15-71518.pdf