Sanjaa v. Sessions

The Ninth Circuit adopted the persuasive reasoning of the Second Circuit and held that the United Nations Convention Against Transnational Organized Crime (UN-CATOC) does not provide an independent basis for relief from removal in immigration proceedings. In this case, the panel denied the petition for review of the BIA's denial of withholding of removal and protection under the Convention Against Torture (CAT). The panel held that the BIA did not err in concluding that petitioner was not persecuted on account of his political opinion, whistleblower status, nor his membership in a particular social group of former police officers. Rather, petitioner's attackers told him that he was being attacked because of his role in a drug-trafficking investigation. The panel also held that, because the UN-CATOC has not been implemented through congressional legislation and was not self-executing as to the relief sought here, petitioner may not rely on its provisions for relief from removal. View "Sanjaa v. Sessions" on Justia Law