Mercado-Martinez

Mercado-Martinez v. Bondi

Good Law
United States Court of Appeals for the Ninth CircuitNovember 19, 202522-53California281 words

Opinion

Opinion

facts.” Gonzalez-Juarez v. Bondi, 137 F.4th 996, 1003 (9th Cir. 2025). Mercado

contends that the agency erred by failing to properly assess the hardship to his U.S.

citizen daughter. He contends that the agency improperly found that hardship to his

daughter would be ameliorated by his reunion with his other children in Mexico and

failed to consider she would lose her only biological parent. Because of this, he

argues, the agency also erred in its cumulative assessment analysis.

We disagree. The BIA independently assessed the harm to each of Mercado’s

qualifying children, and both the BIA and IJ stated they considered the entire record

or totality of the circumstances in reaching their decision. Gonzalez-Juarez, 137

F.4th at 1008 (noting that, although the agency “must consider all of the evidence

22-53 before it,” it need not “individually identify and discuss every piece of evidence in

the record”) (cleaned up). The BIA and IJ expressly considered hardship to

Mercado’s citizen daughter, including the emotional harm of losing visits with her

father, but concluded it was not exceptional or extremely unusual. They also noted

that…

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