African Immigrant Rights Council

FROM THE DESK OF EXECUTIVE DIRECTOR, SHARIFA KALOKOLA

March 7, 2026

No relief for a man threatened by a hitman, because the threats did not cause “actual” harm and because he could have lived elsewhere in his country, to avoid the hitman

A hitman in El Salvador demanded money from Mr. Urias, and shot two of his half brothers. The hitman vowed to kill every member of his family. Mr. Urias moved four times, but each time the hitman found and threatened him. He was beaten when he returned to his hometown for a brief visit. 

The Immigration Judge ruled that Mr. Urias did not suffer enough harm to be deemed “persecution,” in part because Urias had no reports from any doctors, psychiatrists, or psychologists. Also, Urias could have moved farther away from the hitman: only moving to “nearby” areas was insufficient.

The First Circuit Court of Appeals and the Supreme Court did not reverse the decision, because it was not clearly wrong.  Urias-Orellana v. Bondi, 607 U.S. ___ 

(March 4, 2026)

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MORAL OF THE STORY: be prepared to answer these questions:

 If your harm was so bad, why didn’t you go to a doctor, psychiatrist,or a psychologist?

 OK you moved to four different places where the bad guy found you. Why didn’t you go to place # 5, 6, or 7?

Is there anyone who believes the bad guy is still interested in you? Did that person write a letter of support for you? Why not?

If no one in your country believes the bad guy has a present, continuing interest in harming you, why should I, the Judge, believe that?