Cahuana v. Blanche

CourtCourt of Appeals for the Second Circuit
DecidedJune 2, 2026
Docket23-7166
StatusUnpublished

This text of Cahuana v. Blanche (Cahuana v. Blanche) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cahuana v. Blanche, (2d Cir. 2026).

Opinion

23-7166 Sopa-Cahuana v. Blanche BIA Drucker, IJ A220 999 352/353

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 2nd day of June, two thousand twenty- six.

PRESENT: PIERRE N. LEVAL, RAYMOND J. LOHIER, JR., SARAH A. L. MERRIAM, Circuit Judges. _____________________________________

ERLINDA ENCARNACION SOPA- CAHUANA, I.D.B.-S., Petitioners,

v. 23-7166 NAC TODD BLANCHE, ACTING UNITED STATES ATTORNEY GENERAL, 1

1 The Clerk of Court is directed to amend the caption as set forth above. Pursuant to Federal Rule of Appellate Procedure 43(c)(2), Acting Attorney General Todd Blanche is automatically substituted for former Attorney General Pamela Bondi as Respondent. Respondent. _____________________________________

FOR PETITIONERS: Michael Borja, Borja Law Firm, P.C., Jackson Heights, NY.

FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Song Park, Assistant Director; Sanya Sarich Kerksiek, Trial Attorney, Office of Immigration Litigation, United States Department of Justice, Washington, DC.

UPON DUE CONSIDERATION of this petition for review of a Board of

Immigration Appeals (“BIA”) decision, it is hereby ORDERED, ADJUDGED, AND

DECREED that the petition for review is DENIED.

Petitioner Erlinda Encarnacion Sopa-Cahuana and her minor son, natives

and citizens of Ecuador, seek review of an August 23, 2023 decision of the BIA

affirming an August 17, 2022 decision of an Immigration Judge (“IJ”) denying their

applications for asylum, withholding of removal, and relief under the Convention

Against Torture (“CAT”). 2 In re Erlinda Encarnacion Sopa-Cahuana, Nos. A 220 999

2 We do not discuss the CAT claim because, as the Government notes, Sopa-Cahuana failed to exhaust it on appeal to the BIA. See Vera Punin v. Garland, 108 F.4th 114, 124 (2d Cir. 2024) (“[W]hen an argument made to this Court cannot be closely matched up with a specific argument made to the BIA, it has not been properly exhausted and we cannot hear it.”). 2 352/353 (B.I.A. Aug. 23, 2023), aff’g Nos. A 220 999 352/353 (Immig. Ct. N.Y. City

Aug. 17, 2022). We assume the parties’ familiarity with the underlying facts and

procedural history.

Because the BIA summarily affirmed without opinion, “we review the IJ’s

decision as the final agency determination.” Shunfu Li v. Mukasey, 529 F.3d 141,

146 (2d Cir. 2008). We review fact-finding under the substantial evidence

standard and we generally review questions of law de novo. See Hong Fei Gao v.

Sessions, 891 F.3d 67, 76 (2d Cir. 2018); see also Urias-Orellana v. Bondi, 146 S. Ct. 845,

851–54 (2026) (holding that an agency’s persecution determination—both the

factual findings and the application of law to fact—is reviewed under the

substantial evidence standard). “[T]he administrative findings of fact are

conclusive unless any reasonable adjudicator would be compelled to conclude to

the contrary.” 8 U.S.C. § 1252(b)(4)(B).

Sopa-Cahuana does not meaningfully challenge the IJ’s dispositive findings

that she had limited credibility, that her testimony was not sufficiently persuasive,

and that she had not corroborated her claim, i.e., that she did not meet her burden

of proof. An applicant for asylum and withholding of removal has the burden to

establish past persecution or a fear of future persecution, see 8 C.F.R. §§ 1208.13(b),

3 1208.16(b), and that “race, religion, nationality, membership in a particular social

group, or political opinion was or will be at least one central reason for persecuting

the applicant,” 8 U.S.C. § 1158(b)(1)(B)(i); see Quituizaca v. Garland, 52 F.4th 103,

109–14 (2d Cir. 2022) (the “one central reason” standard applies to both asylum

and withholding of removal).

The testimony of the applicant may be sufficient to sustain the applicant’s burden without corroboration, but only if the applicant satisfies the trier of fact that the applicant’s testimony is credible, is persuasive, and refers to specific facts sufficient to demonstrate that the applicant is a refugee. In determining whether the applicant has met the applicant’s burden, the trier of fact may weigh the credible testimony along with other evidence of record. Where the trier of fact determines that the applicant should provide evidence that corroborates otherwise credible testimony, such evidence must be provided unless the applicant does not have the evidence and cannot reasonably obtain the evidence.

8 U.S.C. § 1158(b)(1)(B)(ii); see also id. § 1231(b)(3)(C). A lack of corroboration can

be an independent basis for the denial of relief if the agency identifies reasonably

available evidence that should have been presented, provides the applicant with a

chance to explain the omission, and assesses that explanation. See Wei Sun v.

Sessions, 883 F.3d 23, 31 (2d Cir. 2018).

Sopa-Cahuana references these principles in a perfunctory manner and uses

boilerplate legal language to do so. Such passing references, unconnected to the

4 record and asserted without further development, are insufficient to preserve

review of the burden finding. See Yueqing Zhang v. Gonzales, 426 F.3d 540, 545 n.7

(2d Cir. 2005) (deeming claim “abandoned” when addressed in “only a single

conclusory sentence”). To the extent Sopa-Cahuana argues that she should not

have been required to corroborate her testimony, she ignores that the IJ also found

her claim minimally credible, lacking in persuasiveness, and inherently

implausible. See Garland v. Ming Dai, 593 U.S. 357, 371–72 (2021) (“[E]ven if the

BIA treats an alien’s evidence as credible, the agency need not find his

evidence persuasive or sufficient to meet the burden of proof.”). She has

therefore abandoned review of the burden finding, as she does not explain why

her claim is plausible or address the country conditions evidence, and she does

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Shunfu Li v. Mukasey
529 F.3d 141 (Second Circuit, 2008)
Wei Sun v. Jefferson B. Sessions III
883 F.3d 23 (Second Circuit, 2018)
Garland v. Ming Dai
593 U.S. 357 (Supreme Court, 2021)
Quituizaca v. Garland
52 F.4th 103 (Second Circuit, 2022)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Ud Din v. Garland
72 F.4th 411 (Second Circuit, 2023)
Vera Punin v. Garland
108 F.4th 114 (Second Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Cahuana v. Blanche, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cahuana-v-blanche-ca2-2026.