The First Circuit has remanded a claim for protection under the Convention Against Torture filed by a Haitian citizen, on the ground that the Board of Immigration Appeals failed to address the risk that low-level prison officials would torture the applicant.
The full text of Fleurimond v. Bondi can be found here: https://www.ca1.uscourts.gov/sites/ca1/files/opnfiles/24-1913P-01A.pdf