The Ninth Circuit has denied a petition for review filed by a former Salvadoran police officer threatened by an MS-13 leader for interfering with gang activity, holding that under circuit precedent only threats received after he left the police force are relevant to whether he was targeted on account of his status as a "former" officer, and that no such post-departure threats occurred.
Both members of the panel wrote separately to criticize the rule they felt bound to apply. One judge called it illogical that a petitioner explicitly told to quit the police and leave the country cannot rely on the very threats that drove him to comply, and the other urged the full court to rehear the case en banc to adopt a more nuanced nexus test recognizing that a former officer's status is often inseparable from the actions he took while serving.
The full text of Gonzalez-Argueta v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/08/13/25-557.pdf