The requirement that such persecution be "on account of" is called the nexus requirement, and an applicant must show that "persecution is, at least in part, motivated by a protected ground." Ayala v. U.S. Att'y Gen., 605 F.3d 941, 949 (11th Cir. 2010). 7

The BIA is not required to "address specifically each claim the petitioner made or each piece of evidence the petitioner presented." Ayala v. U.S. Att'y Gen., 605 F.3d 941, 948 (11th Cir. 2010) (quotation omitted). Further, the BIA is not required to make findings on issues unnecessary to the decision it reaches.

8 U.S.C. § 1101(a)(42)(A); see also 8 C.F.R. § 208.13(b)(1), (b)(2)(i)(C). An applicant's failure to report persecution by a private actor to the local authorities is "generally fatal" to her claim, though it may be excused if the she convincingly demonstrates that the government would have been unable or unwilling to protect her. Lopez, 504 F.3d at 1345; Ayala v. U.S. Att'y Gen., 605 F.3d 941, 950 (11th Cir. 2010). We need not address the majority of Bautista-Lopez's claims of error because we affirm the BIA's determination that petitioner cannot demonstrate eligibility for asylum based its finding that she failed to prove the Salvadoran government is unable or unwilling to protect her.

To demonstrate eligibility for asylum based on past persecution, the applicant must present substantial evidence that a past incident or incidents (1) rose to the level of persecution, and (2) were on account of one of the statutorily protected grounds. Ayala v. U.S. Att'y Gen., 605 F.3d 941, 948-49 (11th Cir. 2010). Persecution is an "extreme concept" that requires more than isolated incidents of verbal harassment or intimidation. See, e.g., Kazemzadeh, 577 F.3d at 1353; Djonda v. U.S. Att'y Gen., 514 F.3d 1168, 1171-74 (11th Cir. 2008) (holding that the record did not compel a finding that the petitioner suffered past persecution where the petitioner was detained for thirty-six hours in a small cell shared by twelve people and was beaten twice, once involving a belt and resulting in scratches and bruises); Delgado v. U.S. Att'y Gen., 487 F.3d 855, 859-61 (11th Cir. 2007) (per curiam) (concluding that the record compelled reversal of the BIA's determination that the petitioner did not suffer past persecution based on the cumulative effects of (1) an attack where two men made death threats against the petitioner while pulling the trigger to an unloaded gun, making the petitioner believe the men were going to kill him; (2) an attack that included a severe beating that left the petitioner "almost u

To make that showing, the applicant must "present[] evidence that he reported the persecution to local government authorities or that it would have been useless to do so." Ayala v. U.S. Att'y Gen., 605 F.3d 941, 950 (11th Cir. 2010). Otherwise, an applicant's failure to report persecution by a private actor to the local authorities is "generally fatal" to his claim.

We review only the BIA's decision, except where "the BIA expressly adopted or agreed with the immigration judge's decision." Jathursan v. U.S. Att'y Gen. , 17 F.4th 1365, 1372 (11th Cir. 2021) ; see alsoAyala v. U.S. Att'y Gen. , 605 F.3d 941, 947–48 (11th Cir. 2010). Additionally, where, as here, the BIA issues an opinion relying on the immigration judge's decision and reasoning without expressly adopting that decision, we review the immigration judge's decision to the extent that the BIA found the immigration judge's reasoning was supported by the record, and we review the BIA's decision as to issues on which it rendered its own opinion and reasoning.

We review only the BIA's decision, except to the extent the BIA's decision expressly adopts or agrees with the IJ's opinion. Ayala v U.S. Atty Gen., 605 F.3d 941, 947-48 (11th Cir. 2010).

If the asylum applicant alleges persecution by a private actor, rather than the government, failure to seek protection within his home country is generally fatal to his claim. Id.; see Ayala v. U.S. Att'y Gen., 605 F.3d 941, 950 (11th Cir. 2010). The failure to seek protection in the home country is excused, though, if the applicant "convincingly demonstrates that [home-country] authorities would have been unable or unwilling to protect" him, such that he could not rely on them.

The persecution need not come only from government forces, but can be by non-government groups the government cannot control. See Ayala v. U.S. Att'y Gen., 605 F.3d 941, 948 (11th Cir. 2010). However, "[e]vidence that either is consistent with acts of private violence or the petitioner's failure to cooperate with guerillas, or that merely shows that a person has been the victim of criminal activity, does not constitute evidence of persecution based on a statutorily protected ground."

The BIA and the IJ need not "address specifically each claim the petitioner made or each piece of evidence the petitioner presented, but they must consider the issues raised and announce their decision in terms sufficient to enable a reviewing court to perceive that they have heard and thought and not merely reacted." Ayala v. U.S. Att'y Gen., 605 F.3d 941, 948 (11th Cir. 2010) (quotations and alterations omitted). Where the BIA or the IJ has failed to give "reasoned consideration or make adequate findings," we remand for further proceedings because we are "unable to review the decision."