The Seventh Circuit Court of Appeals ruled on July 1, 2026, against Bojan Andric, a Serbian soccer player seeking asylum in the United States. The court found that Andric did not provide sufficient evidence to support his claims of past persecution due to his identity as a soccer player. This decision affects Andric's future in the U.S. and sets a precedent for similar asylum claims.
Bojan Andric entered the U.S. on a visitor visa and later applied for asylum, claiming he faced violence from soccer hooligans in Serbia. He alleged that these hooligans targeted him because they believed he was “anti-hooligan” and that he had reported them to the police. The case was filed under docket number 25-1448 and was reviewed by Judges Rovner, Jackson-Akiwumi, and Maldonado.
Andric's asylum claim stemmed from an incident where he was attacked by members of a fan group called The Red Devils after a soccer match. He testified that after a game, three Red Devils followed him home, beat him, and threatened him. After the attack, he was hospitalized for injuries including facial burns and a concussion. Despite these events, the immigration judge ruled that Andric's experiences did not amount to past persecution under U.S. asylum law.
The immigration judge found Andric credible but concluded that the harm he suffered did not meet the legal definition of persecution. The judge noted that the attack was a single incident and did not result in lasting harm. Additionally, the judge determined that the hooligans did not target Andric based on a protected ground, such as membership in a social group or political opinion. The judge stated, "Being a soccer player is not an immutable characteristic because it is not so intrinsic or fundamental to identity that it would be unreasonable to require Andric to change occupations to avoid harm."
Andric appealed the immigration judge's decision to the Board of Immigration Appeals (BIA), which upheld the ruling and deemed his revised claim of being a member of “former soccer players in Serbia” as waived. The BIA agreed with the immigration judge's reasoning, stating that Andric had not provided credible evidence that he would face persecution based on his membership in a social group.
In its ruling, the Seventh Circuit reviewed the BIA's decision and noted that Andric's claims did not demonstrate a connection to a protected ground under U.S. asylum law. The court stated, "Any harm Andric fears in either case stems from personal and performance-related grievances, not from membership in a cognizable group." The judges emphasized that personal disputes cannot support an asylum claim.
The court also highlighted Andric's failure to provide evidence that the hooligans would continue to target him if he returned to Serbia or that they would do so based on his status as a former soccer player. The judges concluded that Andric's experiences were related to individual performance rather than a recognized social group, stating, "A personal dispute cannot support an asylum claim."
This ruling has significant implications for Andric and others who may seek asylum based on similar claims. It clarifies that not all instances of violence or harassment qualify for asylum protection, especially if they are rooted in personal grievances rather than systemic persecution based on immutable characteristics.
The court's decision may also influence future asylum cases involving individuals from countries with issues related to sports violence and hooliganism. It sets a precedent that emphasizes the need for asylum seekers to demonstrate that they are targeted based on recognized social groups or political opinions, rather than individual disputes.
Looking ahead, Andric may have limited options for appeal, as the Seventh Circuit's ruling is typically final unless new evidence emerges or there are significant legal changes. There are currently no related cases pending that could affect this ruling.
In conclusion, the Seventh Circuit's decision to deny Bojan Andric's asylum claim underscores the stringent requirements for asylum seekers in the U.S. and the importance of demonstrating a clear connection to protected grounds for persecution.