Singh v. Blanche

── Singh v. Blanche ── Court: Court of Appeals for the Ninth Circuit Date: May 15, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT BALJIT SINGH, No. 24-815 Agency No. Petitioner, A208-180-861 v. AMENDED OPINION TODD BLANCHE, Acting Attorney General, Respondent. On Petition for Review of an Order of the Board of Immigration Appeals Submitted October 20, 2025 * Pasadena, California Filed December 1, 2025 Amended May 15, 2026 Before: Ryan D. Nelson and Lawrence VanDyke, Circuit Judges. ** * The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). ** This opinion was originally issued by a unanimous panel that included Judge Sandra S. Ikuta. Following Judge Ikuta’s death, this amended 2 SINGH V. BLANCHE Opinion by Judge R. Nelson; Concurrence by Judge VanDyke SUMMARY *** Immigration In an amended opinion, the panel denied Baljit Singh’s petition for review of the Board of Immigration Appeals’ decision affirming the denial of asylum and related relief, concluding that substantial evidence supported the BIA’s determination that Singh’s past incidents did not rise to the level of past persecution and that he could avoid future persecution by relocating within India. In Urias-Orellana v. Bondi, 146 S. Ct. 845 (2026), the Supreme Court unanimously held that the substantial evidence standard applies to the agency’s conclusion that a given set of undisputed facts does not constitute persecution. The panel explained that this standard applies to the entirety of the agency’s conclusions—both the underlying factual findings and the application of the Immigration and Nationality Act to those findings. In so holding, the Supreme Court abrogated this court’s contrary holdings, and to the extent there was intra-circuit tension on this issue, there no longer is. Likewise, the court reviews the BIA’s findings on internal relocation for substantial opinion is issued by a quorum of the panel. See 28 U.S.C. § 46(d); Ninth Circuit General Order 3.2(h). *** This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  SINGH V. BLANCHE 3 evidence, a highly deferential standard under which the BIA’s findings are conclusive unless a reasonable adjudicator would be compelled to conclude the contrary. Substantial evidence is more than a mere scintilla, but means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The panel held that the incidents Singh experienced, including a vague threat by unknown individuals, two apparently unrelated physical assaults by unknown individuals without serious injuries, and a brief police detention, over an eleven-month period, did not compel a finding of past persecution. The panel wrote that the connection between the incidents was tenuous and noted that the court has declined to reverse the agency's conclusion on past persecution in cases with similar levels of cumulative harm. Although a reasonable factfinder could have found the incidents sufficient to establish past persecution, a factfinder would not be compelled to do so. The panel rejected Singh’s contention that the agency erred by ignoring factors from related precedent involving harm to Mann political party members in the Punjab. The BIA was not required to use these factors as a special rule for all Mann party Sikhs from Punjab