The Board of Immigration Appeals has determined that disapproval of or opposition to criminal gangs is not sufficient to establish a political opinion under the INA. To establish a political opinion, the applicant must have an actual or imputed belief or conviction regarding a discrete cause that is tied to the government of a country, including a de facto government.
The Board rejected the argument that opposition to the Maras and their activities in El Salvador constituted a political opinion, finding that the record did not establish that gangs in El Salvador exercise actual sovereignty or control such that they constitute a de facto government. The Board also rejected the respondent’s gender- and family-based particular social group arguments under recent Board and Attorney General precedent, and affirmed the denial of CAT protection.
The full text of Matter of D-G-E-A- & N-G-G-E- can be found here: https://www.justice.gov/eoir/media/1436936/dl?inline