The First Circuit has dismissed in part and denied in part a petition for review filed by a Jamaican man whose brother's work as a police officer investigating gangs allegedly made the family a target, holding that it lacks jurisdiction over the agency's discretionary denials of adjustment of status and untimely asylum, and separately upholding the denial of withholding of removal.
The Court held that the petitioner's proposed social group of the immediate family of police officers who have resisted corruption and gang activity lacked the required particularity, since the concept of "resisting" corruption is too amorphous to delineate group membership, drawing on the Court's rejection of similarly vague resistance-based groups in prior cases. The Court also upheld the agency's adverse credibility finding based on multiple inconsistencies in the petitioner's and his brother's testimony, and rejected his argument that the agency applied the wrong circuit's law, since the immigration judge had analyzed the claims under First Circuit precedent in the alternative.
The full text of Bromfield v. Blanche can be found here: https://www.ca1.uscourts.gov/sites/ca1/files/opnfiles/25-1556P-01A.pdf