The Fifth Circuit has determined that a Salvadoran respondent's untimely motion to reopen did not qualify for the changed country conditions exception. The respondent argued that he faced increased danger in El Salvador after his father-in-law, an alleged former MS-13 official, was arrested and extradited to the United States, causing MS-13 to believe that the father-in-law had cooperated with the FBI.
The Court found that the father-in-law's arrest and extradition were changes in the respondent's personal circumstances, not changed country conditions in El Salvador. Although the respondent may now face greater danger, the danger flowed from a family-specific development, rather than from a material nationwide change in conditions. The Court also rejected the respondent's request for equitable tolling, finding that he did not establish that former counsel's alleged ineffectiveness prevented him from timely filing the motion to reopen.
The full text of Prado-Majano v. Blanche can be found here: https://www.ca5.uscourts.gov/opinions/pub/25/25-60040-CV0.pdf