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Yi Fu Zheng v. Holder

Citation: 349 F. App'x 560Docket: No. 09-0874-ag

Court: Court of Appeals for the Second Circuit; October 16, 2009; Federal Appellate Court

Narrative Opinion Summary

In this immigration case, the petitioner, a Chinese national, sought review of the Board of Immigration Appeals' (BIA) decision denying his motion to reopen immigration proceedings. The petitioner's motion, filed in November 2008, was ruled untimely as the final order of removal dated back to June 2002, and the petitioner did not satisfy the criteria for an exception based on changed country conditions. The petitioner argued that his recent conversion to Roman Catholicism and increased religious devotion constituted changed personal circumstances. However, the BIA found these factors insufficient to demonstrate a change in conditions in China that would warrant reopening the case. The BIA referenced U.S. State Department Reports from 2007 and 2008 indicating improved relations between Chinese Catholic clerics and the Vatican, which contradicted the petitioner's claims. The court upheld the BIA's decision, emphasizing that the BIA is not required to address every piece of evidence if it provides reasoned consideration. The petition for review was denied, and any previously granted stay of removal was vacated, with pending motions dismissed as moot. The request for oral argument was also denied.

Legal Issues Addressed

Changed Country Conditions Exception

Application: The court found that personal changes, such as religious conversion, did not constitute a change in country conditions necessary to reopen the case.

Reasoning: Zheng's claims of a change in personal circumstances, including his confirmation as a Roman Catholic in the U.S. and increased religious devotion, were not considered sufficient evidence of changed conditions in China.

Evaluation of Evidence by the Board of Immigration Appeals

Application: The BIA is not obligated to address every piece of evidence if reasoned consideration is given to the case.

Reasoning: The BIA is not required to address every piece of evidence or argument presented by the petitioner, provided it gives reasoned consideration to the case.

Motions to Reopen Immigration Proceedings

Application: The court evaluated the timeliness of the motion and the exceptions based on changed country conditions, ultimately finding the motion untimely without applicable exceptions.

Reasoning: Zheng's motion, filed in November 2008, was deemed untimely since the final order of removal was issued in June 2002, and he did not qualify for an exception based on changed country conditions.

Reliability of Country Reports

Application: The BIA relied on U.S. State Department Reports indicating improved relations between Chinese Catholic clerics and the Vatican, countering Zheng’s claims.

Reasoning: The BIA referenced U.S. State Department Reports from 2007 and 2008, which indicated that relationships between Chinese Catholic clerics and the Vatican had improved, contradicting Zheng's assertions of worsening conditions for Catholics.