The petitioner was threatened with harm on account of her relationship to her uncle, who had been extorted by gang members.  However, because the petitioner testified that the sole reason the gang had targeted her uncle was to extort money from him, not because he belonged to her family, the Eighth Circuit found that any harm she might suffer would not be account of her family ties.  The court also deemed the group insufficiently particularized because it was "unclear whether the gang members were attempting to threaten Milian's nuclear family, her uncle's family, or their entire extended family."

The full text of Milian v. Lynch can be found here: