The Fourth Circuit has granted a petition for review filed by a Salvadoran mother and her children denied asylum after a man threatened them in retaliation for her former partner's affair with the man's wife, holding that the agency legally erred by analyzing why the persecutor targeted the former partner rather than why he threatened the family.
The Court held that the nexus inquiry must focus on the persecutor's reasons for targeting the petitioner herself, and that the record compelled a finding that the petitioner was threatened solely because of her family relationship to her former partner, satisfying the "at least one central reason" standard even though the underlying dispute stemmed from personal matters between the men. A concurring judge wrote separately to flag, for future cases, that the government may be able to defend an agency ruling on grounds the agency did not itself invoke following the Supreme Court's decision in FDA v. Wages and White Lion Investments.
The full text of Orellana-Ramos v. Blanche can be found here: https://www.ca4.uscourts.gov/opinions/252320.P.pdf