The Seventh Circuit has dismissed in part and denied in part a petition for review filed by an Indian Muslim who sought asylum, withholding of removal, and CAT protection. The Court held that it lacked jurisdiction to review the determination that the asylum application was untimely, because the petitioner did not develop any argument that recent Supreme Court authority had altered the Court's prior jurisdictional rule. The Court did note that a circuit split exists on this issue, and that it will eventually have to address it head on.
The Court also upheld the denial of withholding of removal. The petitioner's single beating, which resulted in minor injuries, did not compel a finding of past persecution, particularly where police stopped the attack and the business that allegedly motivated the harm was no longer operating. The Court further found that the agency reasonably determined that the petitioner could relocate within India.
The full text of Mohammed v. Blanche can be found here: https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D05-05/C:25-1901:J:Scudder:aut:T:fnOp:N:3535996:S:0