The Ninth Circuit has determined that substantial evidence review applies to the agency's conclusion that undisputed facts do not rise to the level of persecution. The Court explained that, under Urias-Orellana v. Bondi, the agency's application of the INA to established facts is reviewed under the substantial evidence standard, abrogating any prior Ninth Circuit precedent that may have applied de novo review.
Applying that standard, the Court upheld the denial of asylum, withholding of removal, and CAT protection to a Sikh man from Punjab who supported the Mann Party. The Court found that the record did not compel a conclusion that threats, two beatings, and a one-night police detention amounted to past persecution. The Court also held that the agency reasonably found that the petitioner could relocate within India, and rejected the argument that the agency was required to apply a special Mann Party relocation rule to all Sikh applicants from Punjab.
The full amended text of Singh v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/05/15/24-815.pdf