Jose Rivera sought protection from removal based on his fear that gangs in El Salvador would seek to kidnap or extort him because they would perceive him as wealthy, owing to his long residence in the United States.  Though the Seventh Circuit ultimately determined that Rivera had not proven he would be targeted by gang members because of the perception that he is wealthy, the Court made the following observations that should give home for future applicants.  "We are dubious . . . of the proposition announced in some cases that the status of being a member of a group made up of individuals deported from the United States who, having lived in this country for many years, either have money or are believed to have money and have long‐established ties to this country, and who for any of these reasons might be able to pay ransom, nevertheless can’t be deemed members of a 'social group' authorized to obtain relief from deportation because of threats to the life or safety of the group’s members."  "We note finally, for its possible relevance in future cases, that what doesn’t matter in the case of an illegal immigrant resisting removal because of fear of persecution is whether gangs in El Salvador, or whatever the immigrant’s country of origin is, are wrong in thinking that anybody who’s lived in the United States is likely to be wealthy or have wealthy American connections. If thatʹs what the gangs think, and if (a big if, which requires evidence) as a result they hold deportees from the U.S. for ransom and kill them if it isnʹt paid, those deportees are being subjected to persecution. We don’t think either a court or the immigration agencies could rationally deny that. But it isn’t this case."

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