Tuesday, October 7

Sixth Circuit denies asylum petition of Bangladeshi man over family land dispute

CINCINNATI, OH – The United States Court of Appeals for the Sixth Circuit has denied Masud Ahmed’s petition for review of a Board of Immigration Appeals decision that upheld the denial of his asylum, withholding of removal, and protection under the Convention Against Torture.

According to court records (Case No. 25-3074), Ahmed, a native and citizen of Bangladesh, fled to the United States in 2016 after a violent dispute with his paternal cousins over family property. Following the death of his father, Ahmed’s mother transferred ownership of their home to him, prompting anger from relatives who wanted the property for themselves. Ahmed alleged that the cousins later assaulted him after he reported threats to local authorities, and that police refused to intervene due to the cousins’ political connections.

An Immigration Judge denied Ahmed’s request for relief, finding that his persecution claims stemmed from a personal family dispute rather than from membership in a protected social group. The judge also found that Ahmed could safely relocate within Bangladesh and that his claims did not meet the criteria for protection under the Convention Against Torture. The Board of Immigration Appeals affirmed the decision.

The Sixth Circuit, in an opinion by Judge Mathis joined by Judges Nalbandian and Ritz, concluded that Ahmed failed to show a nexus between his harm and a protected ground such as political opinion or social group membership. The court found that the threats and assault arose from “personal reasons, not on account of a protected ground,” and cited precedent holding that land or inheritance disputes do not qualify as persecution under the Immigration and Nationality Act.

Because Ahmed did not properly exhaust his claim for protection under the Convention Against Torture, the court declined to consider it. The petition for review was denied.

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