The Eighth Circuit has denied a petition for review filed by a Guatemalan mother and son fleeing a violently abusive partner, holding that substantial evidence supported the agency's finding that the partner's abuse was not shown to be centrally motivated by the petitioner's membership in proposed social groups of Guatemalan women.
The Court held the record instead supported that the partner's violence correlated with his substance abuse and jealousy-driven accusations of infidelity, patterns the court had previously found insufficient to establish nexus in a similar case, and that Guatemala's establishment of victim service centers, femicide criminalization, and specialized courts undercut the petitioner's claim that the government would acquiesce in any future torture.
The full text of Matias-Pablo v. Blanche can be found here: https://ecf.ca8.uscourts.gov/opndir/26/08/252021P.pdf