Kanugu provided financial support to a group of vigilantes who opposed the Munguki, a powerful organized crime group in Kenya. For his opposition, he was kidnapped and his daughter was raped by the Munguki. However, because he agreed with the Immigration Judge's characterization of his particular social group as "individuals who were openly opposed to the Munguki sect," the Immigration Judge determined that the group was too diffuse to qualify as a particular social group for asylum purposes. The Eighth Circuit would not permit Kanugu to narrow the parameters of the group on appeal. Thus, it affirmed the denial of his asylum application.
The full text of Kanugu v. Holder can be found here: http://media.ca8.uscourts.gov/opndir/15/02/133563P.pdf