In the Ninth Circuit, an asylum applicant can prove a well‑founded fear without showing individualized targeting by establishing a “pattern or practice” of persecution against a protected group in their home country. This doctrine is especially important when the applicant’s past harm is limited, but country conditions show systematic violence or repression. This 2026 update […]
In U.S. asylum cases involving MS‑13 or Barrio 18, applicants often win “government unable or unwilling to protect” by documenting repeated failed police reports, credible country-condition evidence, and specific links between gangs and state actors. This issue is central for many Salvadoran claims where applicants did not receive meaningful protection despite seeking help. This article
Winning an asylum case based on Salvadoran gang extortion threats usually turns on 3 proof points: credible testimony, a legally valid protected ground (often a PSG), and a clear nexus showing “one central reason” for the harm. In practice, MS-13 and Barrio 18 extortion claims fail most often on nexus and PSG framing—not on fear.
