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Zhi Hao Liu v. Holder

Citation: 319 F. App'x 77Docket: No. 05-2890-ag

Court: Court of Appeals for the Second Circuit; April 7, 2009; Federal Appellate Court

Narrative Opinion Summary

The petitioner, a Chinese national, sought judicial review of a Board of Immigration Appeals (BIA) order affirming the denial of his application for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). The BIA upheld the Immigration Judge's (IJ) decision, which was based on an adverse credibility determination supported by substantial evidence. Inconsistencies in the petitioner's statements regarding his marital status and the legitimacy of his marriage certificate were significant factors in the credibility assessment. The petitioner failed to provide corroborative evidence for his claims of government fines and sterilization practices, which further undermined his credibility. Additionally, he did not contest the denial of his CAT claim, resulting in its waiver. The adverse credibility determination also affected the withholding of removal claim, as it was based on the same facts as the asylum claim. Consequently, the petition for review was denied, and the previously granted stay of removal was vacated.

Legal Issues Addressed

Adverse Credibility Determination

Application: The Immigration Judge’s adverse credibility determination was upheld due to substantial evidence, including inconsistencies in the petitioner's statements regarding his marital status and the legitimacy of his marriage certificate.

Reasoning: The IJ’s adverse credibility determination was supported by substantial evidence, particularly Liu's inconsistent statements regarding his marital status and the legitimacy of his marriage certificate.

Corroborative Evidence Requirement

Application: The petitioner’s failure to provide corroborative evidence for claims of government fines and sterilization practices impacted his credibility and supported the adverse credibility determination.

Reasoning: Additionally, Liu failed to provide corroborative evidence for claims of government fines and sterilization practices, and he did not contest these findings, which further impacted his credibility.

Impact of Credibility on Withholding of Removal

Application: The adverse credibility determination precluded success on the withholding of removal claim, as it relied on the same factual basis as the asylum claim.

Reasoning: The IJ's adverse credibility determination precluded success on Liu’s withholding of removal claim, as both claims relied on the same factual basis.

Review of BIA and Immigration Judge Decisions

Application: The court reviews the Immigration Judge’s decision as modified by the Board of Immigration Appeals’ (BIA) findings.

Reasoning: The court reviews the IJ's decision as modified by the BIA's findings.

Waiver of Claims

Application: The petitioner's claim under the Convention Against Torture was deemed waived because it was not contested in the brief.

Reasoning: Liu's CAT claim was deemed waived as he did not contest its denial in his brief.