the court my name is maria bald men and i represent petitioner here us in this particular case there are three issues that i would like to address the first is whether the board erred as a matter of law in failing to properly consider this court's recent precedent and two cases and apply it to the record evidence this constitutes a question of law over which this court does have jurisdiction despite m misdemeanor possession for cocaine conviction from two thousand and five the second issue that i would like to address is whether the board as a matter of law by affirming the judge's decision and holding that petitioner at demonstrators that it would be unreasonable for had not demonstrated that it would be unreasonable for him said relocate outside of his home town in mexico in america cruise in particular and the third issue that i like to address is the issue of the case the immigration found all of the witnesses credible do not dispute the country reports or the numerous published articles that were submitted demonstrating violence in mexico and back in vera cruz and hiding because that is where he had family and that is all the information the family has since provided to me now couldn't the i guess what the what the government argues is that he could he could relocate to some other place where the status are less active yes your honor and one of the places that the immigration judge had found that he could relocate  penetrating mexico since two thousand and six and the mexican army have sent was sent in to the state of our crews followed by the mexican marines to try to fight against zeta so you're correct your maybe safer there your honor but having lived in the united states since one thousand nine hundred six when he returned when he was deported back to mexico one of the issues that he testified to was that he would be perceived as returning from the u s because he didn't have any ties anywhere else in the country besides very there are a cruise is a lock and mexico city he would be seen as an outsider moving into the area outside so your honors we submit that he the board did not consider all of the factors under the regulation regarding internal relocation and whether it was reasonable or not one of the other issues that arises in this case was both he and his girlfriend had testified that the u s citizen children who were teenagers would also return with them to keep the family together because they were very close the kids would stand out from other children in mexico as they speak english as their first language dress differently and act differently the board the immigration judge in this particular case relied on his three years of college education to become an electrician and his different types of employment in the us mr saw that it was deported as a forty year old man he was not deported as someone in the eight the age range of twenty of his twenty's here the other issue that the board had ignored was the conditions throughout mexico inus decision didn't address directly the extensive evidence that we provided it demonstrating the cartel wars throughout the country of mexico or the governments know it inability to control the zetas in particular this court did address that the as far as it would be in danger if they would be in danger of torture upon his return to mexico and noted that in particular the applicant for relief under the convention against torture does not have to prove of that the mexican federal government could not protect him from torture if he demonstrated that the local law enforcement is corrupt and working with the cartels and therefore unable to protect people from torture this court used rather strong language about the situation in mexico and the cartels targeting people in mexico who have returned from the u s based on the  different than petitioners case but the fact remains that the mexican government is unable to control the cartels and it's corrupt law enforcement agents at both the local levels and the federal levels and we to reverse the board's finding on its cat holding in particular with respect to the issue of membership in a particular social group the board had already made its decision the government to not file a motion to remain with this court for it to for the board to consider domingo's to lead and we ask that the court not rely on that because the government did not the board did not have the opportunity to address that particular issue with respect to matter of w g r the board had affirmed the immigration judge's findings that petitioners particular social particular social purpose she had and therefore she denied withholding of removal on that issue we asked the court to reverse the board's decision on the particular social group and find out the particular social group  is not a recent arrival he's not someone who's been here a short time he was in the united states for twenty years before he was deported from the united states thank you for honour's ok thank you very much good morning your honour's may please the court carrie monaco representing the respondent attorney general loretta lynch the petitioner does not dispute that he has been convicted of an offense involving a controlled substance nor does he dispute that as a result of that conviction that he that this court's jurisdiction is limited to questions of law or constitutional claims raised in his petition for a view as discussed in the government's brief the petitioner has failed to raise any reviewable questions of law or mexico where the record evidence shows that there are numerous areas within mexico that are not controlled by the zetas then we point to that evidence in our brief specifically on page nine fifty there's an art the immigration service seems to think it's really easy to locate yourself in a foreign country that's true he's going to come into some town he's never been in and the locals are going to  wonder who is this guy right where he says well there's no evidence that anyone would be interested in hell just you know it's your common sense how it feels to be relocating within a country like mexico i mean i don't know how that would be different than relocating in other countries people who have to didn't think there's any difference between mexico say and canada well what i'm saying is that i'm not sure that moving to another city is going to raise any other questions than what happened to be asked by the locals who liers where he's from right country in the world i wouldn't i would imagine so and that's exactly my point that i'm not sure it would raise any other questions than the people moving in any other country and or you know about this country or any other i don't know what would happen the question though is for this form of relief who would be targeting him and where and his claim is that the zetas would target him throughout the entire country of mexico but as the agency found the well the court found in an l a i don't want a court fight give me an example of what you consider to be an immutable characteristic brace for example land ownership this court has found land ownership right i mean if the sex based persecution claims as a viable grounds might correct so why can't you just say that you don't have to have an immutable characteristic to be protected because from well i mean there's three different factors that the agency looks at in determining whether it's a it's a social group and  what's the issue in this case though is not involved in the necessarily the definition of a particular social group because we have two dispositive findings the nexus finding and the internal relocation finding that prevent petitioner from winning on petition for review right why don't we don't do you know only proper issue whether he uses significant danger here is a beautiful or well and our argument i that the issue is that if he hasn't proven that he's in danger because he hasn't shown a nexus to a protected ground and he hasn't shown that he's unable to avoid persecution or torture by relocating within another area of the country and nor do the country conditions support his claim that he has a substantial risk of being persecuted or tortured the entire country of mexico by the zetas which is the group that he specifically fears but again this court's jurisdiction is limited to questions of law unconstitutional claims and the petitioners claims are essentially challenges to the weighting of evidence that the immigration judge did in his decision that the board affirmed my opposing counsel is arguing that there's a legal error because the immigration judge did not give enough weight to certain evidence and gave too much weight to other evidence but this court has made clear that that is a factual question over which it does not have jurisdiction and because  jurisdiction is limited to questions of law pure questions of law the court has made very clear mix questions of law are not within the scope of jurisdiction in this case because the court's jurisdiction is limited to questions of law and because petitioner has not raised any mexico where he can ignore the where he can be safe from the long arm to allow him to return to united states i mean he would have to demonstrate it if we're talking about the withholding of removal claim he would still have to demonstrate that there's a between the zetas harming him and a protected ground general criminal violence is not enough for the withholding of a mobile standard there has to be a connection to particular social group or some other protected ground which he has no i'm no such supposing that there's no push in mexico where he would be safe from these years with that be enough to entitle him to cancellation of withholding and well i mean i think we have to look at why he wouldn't be safe from the zetas is it just because they want to kill him they don't like him specifically because he addition would he have to show the size that is life was in danger that he's being targeted for some reason other than just general criminal violence that may occur throughout my god i don't know they don't like him it's not that he's just some weird nary person they bumped off to they don't like him they hate they want to kill is there enough to be a target of the say there's is that enough to think you know the the level of harm or the likelihood of harm that he must show under a withholding claim or a cat claim is much more significant than an aside i want him to do that that i am assuming that and they have a long arm and they're violent and they have a good shot at killing him if that's true isn't that enough for withholding or for yes to simply answer your yes that's why once you mean that you mean that we give no protection to foreigners to deportees who are in danger of death unless they belong to a social group that is the legal requirements your honor yes it's true that make any possible sense and this is the statutory scheme that congress set forward that the board has affirmed that can't imagine sending innocent people to their death well and that they don't belong to a social and that's what convention against torture claims are for you don't have to prove a social group for that you would have to prove the likelihood of torture you don't have to prove that feared prosecution and torture by corrupt government officials who are working in conjunction with the slightest amount was raised at the i j a level before the board and again in their motions supplement based on this court's recent decisions as far as  protection to deportees under the convention against torture and that is correct and we would ask the court to look closely at both the cat claim and the particular social group issue and reverse the board on its findings thank and it was stopped by some townspeople on the streets and has nephew israel was kidnapped at the end of two thousand october two thousand and fourteen or november two thousand and fourteen getting a number two thousand and fourteen there's no evidence that either of those