What happened
The Seventh Circuit denied Serbian professional soccer player Bojan Andric's petition for review of a Board of Immigration Appeals order rejecting his asylum claim, holding that violence and threats he attributed to soccer hooligans were not tied to a protected ground under the immigration laws.
Andric said he entered the United States on a visitor visa and sought asylum after claiming that Serbian soccer hooligans beat him, threatened him and viewed him as anti-hooligan or as someone who had reported them to police. Judge Ilana Rovner, writing for a panel that included Judges Candace Jackson-Akiwumi and Nancy Maldonado, said the record did not compel overturning the agency's rejection of his claim.
The panel said it did not need to decide whether the assault and threats amounted to past persecution because the alleged harm was not because of a statutorily protected ground. Andric had framed the case around a proposed social group of Serbian soccer players who were victims of violence from soccer hooligans, later shifting to former soccer players in Serbia.
The court said Andric conceded that being a professional soccer player is not immutable, and it held that his revised proposed group of former soccer players was waived because he had not presented it to the immigration judge. The panel also said both formulations failed on the merits because the alleged danger stemmed from poor play and angry fans, not group membership. "A personal dispute cannot support an asylum claim."
The panel also found that Andric waived his imputed-political-opinion argument in the Seventh Circuit and, in any event, had not shown that the hooligans were motivated by a political opinion they attributed to him rather than by his performance.
The decision carries a secondary warning for immigration adjudication. The panel criticized immigration judges' use of boilerplate addenda of law, saying the format complicates meaningful review by forcing the Board or reviewing court to connect factual and legal conclusions to authorities listed elsewhere. But the Seventh Circuit declined to reject the practice in this case, saying a more explicit bridge would not have changed the outcome.