The U.S. Supreme Court unanimously ruled in favor of the federal government in Urias-Orellana v. Bondi, clarifying how federal courts should review asylum decisions. Writing for the court, Justice Ketanji Brown Jackson explained that appellate courts must apply a deferential “substantial evidence” standard when evaluating whether asylum seekers have proven persecution. The case involved Douglas Humberto Urias-Orellana, his wife Sayra Iliana Gamez-Mejia, and their child, who fled El Salvador in 2021 due to fears of violence. Urias-Orellana said a hired killer, or sicario, had targeted his family and had already murdered two of his half-brothers. He also reported that associates of the hitman repeatedly demanded money and once attacked him.
Under the Immigration and Nationality Act, asylum applicants must show they suffered persecution or have a well-founded fear of persecution based on factors such as race, religion, nationality, political opinion, or membership in a particular social group. An immigration judge concluded that Urias-Orellana’s experiences did not meet the legal standard, partly because the family had previously relocated within El Salvador to avoid danger. The Board of Immigration Appeals upheld that decision in 2023 and ordered the family’s removal.
Afterward, the family sought review in federal court, ultimately bringing the case before the Supreme Court to resolve disagreement among appellate courts about how persecution findings should be reviewed. The justices ruled that the law requires courts to defer to agency fact-finding unless the evidence clearly demands a different conclusion. Jackson emphasized that such decisions may only be overturned if any reasonable adjudicator would be compelled to reach the opposite conclusion, reaffirming the standard established in INS v. Elias-Zacarias.
