The Fourth Circuit has denied a petition for review filed by a Guatemalan man who fled after MS-13 members assaulted him and demanded extortion payments, threatening to recruit him because he could not pay. He sought asylum based on membership in social groups of Guatemalan youths and youths who resist gang recruitment.
The Court held that substantial evidence supported the agency's finding that the gang targeted the petitioner for money and to grow its ranks generally, not because of his age or his resistance to recruitment specifically, since his own testimony described an indiscriminate extortion scheme applied to everyone in the gang's territory. The Court explained that a general country-conditions report on gang recruitment of youth could not compel a contrary, petitioner-specific finding of nexus, and separately upheld the denial of CAT protection based on evidence that Guatemalan police make genuine efforts to combat gang violence.
The full text of Flores-Turcios v. Blanche can be found here: https://www.ca4.uscourts.gov/opinions/241338.P.pdf