The Seventh Circuit has denied a petition for review filed by a Serbian professional soccer player who sought asylum after being beaten by a violent fan group dissatisfied with his on-field performance. The immigration judge found the petitioner's account of the attack and subsequent threats credible but concluded he had not established persecution on account of a protected ground.
The Court agreed that neither "soccer players" nor "former soccer players" constitutes a cognizable particular social group, since the harm the petitioner feared stemmed from personal, performance-related grievances rather than an immutable characteristic. The Court also found the petitioner's imputed political opinion argument undeveloped and waived. Separately, the Court expressed concern about immigration judges' growing practice of appending boilerplate legal citations in a separate document from their factual findings, though it declined to disturb the outcome here since the result would not have changed.
The full text of Andric v. Blanche can be found here: https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D07-01/C:25-1448:J:Rovner:aut:T:fnOp:N:3567073:S:0