Huang v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedApril 30, 2025
Docket23-6540
StatusUnpublished

This text of Huang v. Bondi (Huang v. Bondi) 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
Huang v. Bondi, (2d Cir. 2025).

Opinion

23-6540 Huang v. Bondi BIA Christensen, IJ A208 599 545

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 30th day of April, two thousand twenty-five.

PRESENT: DENNIS JACOBS, JOSEPH F. BIANCO, MYRNA PÉREZ, Circuit Judges. _____________________________________

ZHONG HUANG, Petitioner,

v. 23-6540 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Gerald Karikari, Esq., New York, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Brianne Whelan Cohen, Senior Litigation Counsel; Nicole Thomas- Dorris, 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 Zhong Huang, a native and citizen of the People’s Republic of

China, seeks review of a May 12, 2023 decision of the BIA, affirming a May 11, 2018

decision of an Immigration Judge (“IJ”), which denied his application for asylum,

withholding of removal, and relief under the Convention Against Torture

(“CAT”). In re Zhong Huang, No. A208 599 545 (B.I.A. May 12, 2023), aff’g No.

A208 599 545 (Immig. Ct. N.Y. City May 11, 2018). We assume the parties’

familiarity with the underlying facts and procedural history.

We have considered both the IJ’s and the BIA’s opinions. See Wangchuck v.

Dep’t of Homeland Sec., 448 F.3d 524, 528 (2d Cir. 2006). “We review de novo

questions of law and the application of law to fact,” and “factual findings,

including adverse credibility findings, under the substantial evidence standard.”

Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018) (citation omitted). “[T]he

2 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).

“Considering the totality of the circumstances, and all relevant factors, a

trier of fact may base a credibility determination on the demeanor, candor, or

responsiveness of the applicant or witness, . . . the consistency between the

applicant’s or witness’s written and oral statements (whenever made and whether

or not under oath, and considering the circumstances under which the statements

were made), the internal consistency of each such statement, the consistency of

such statements with other evidence of record . . ., and any inaccuracies or

falsehoods in such statements, without regard to whether an inconsistency,

inaccuracy, or falsehood goes to the heart of the applicant’s claim, or any other

relevant factor.” 8 U.S.C. § 1158(b)(1)(B)(iii). “We defer . . . to an IJ’s credibility

determination unless, from the totality of the circumstances, it is plain that no

reasonable fact-finder could make such an adverse credibility ruling.” Xiu Xia

Lin v. Mukasey, 534 F.3d 162, 167 (2d Cir. 2008); accord Hong Fei Gao, 891 F.3d at 76.

Substantial evidence supports the agency’s adverse credibility

determination given inconsistencies between Huang’s and his cousin’s accounts

and the lack of other reliable corroboration. Huang testified that he was

3 persecuted in China for practicing Christianity, and that he continued to practice

Christianity in the United States. He presented his cousin as a witness to that

practice, testifying that they attended church together the day before the hearing,

but that his cousin usually lived out of state. The agency reasonably relied on the

inconsistencies between Huang’s and his cousin’s testimony, 8 U.S.C.

§ 1158(b)(1)(B)(iii), which cast doubt on whether they were together that day.

Huang testified that he and his cousin attended church the day before the

hearing from 1:00 to 2:30 p.m., where they heard a sermon about Noah

establishing a covenant with God. The IJ specifically asked Huang if he did

anything before attending church, including if he had eaten, and Huang answered

no. Huang then stated that he ate for the first time at a restaurant after church

around 3:00 p.m., and that he and his cousin then went home, but went back to the

same restaurant for dinner. Certified Administrative Record at 142–47.

Huang’s cousin, on the other hand, testified that they ate breakfast together at a

“fast food store” and then went to Huang’s lawyer’s office before attending church

(where they discussed the covenant between God and Noah). Id. at 156. After

church, they went directly home. Their next meal was that evening, and they ate

at a different restaurant from the earlier meal.

4 The agency “may rely on any inconsistency or omission in making an

adverse credibility determination as long as the ‘totality of the circumstances’

establishes that an asylum applicant is not credible.” Xiu Xia Lin, 534 F.3d at 167

(quoting 8 U.S.C. § 1158(b)(1)(B)(iii)). These several inconsistencies provide

substantial evidence for the adverse credibility determination because they

undermine the reliability of Huang’s and his cousin’s testimony about whether

they attended church that day and more broadly call into question whether Huang

is a practicing Christian. See Likai Gao v. Barr, 968 F.3d 137, 145 n.8 (2d Cir. 2020)

(“[E]ven a single inconsistency might preclude an alien from showing that an IJ

was compelled to find him credible. Multiple inconsistencies would so preclude

even more forcefully.”); Siewe v. Gonzales, 480 F.3d 160, 170 (2d Cir. 2007) (“[A]

single false document or a single instance of false testimony may (if attributable to

the petitioner) infect the balance of the alien’s uncorroborated or unauthenticated

evidence.”). Contrary to Huang’s argument here, an inconsistency need not go

to the heart of the claim. See 8 U.S.C. § 1158(b)(1)(B)(iii) (allowing reliance on

inconsistencies “without regard to whether an inconsistency, inaccuracy, or

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Related

Biao Yang v. Gonzales
496 F.3d 268 (Second Circuit, 2007)
Xiu Xia Lin v. Mukasey
534 F.3d 162 (Second Circuit, 2008)
Liu v. Eric H. Holder Jr.
575 F.3d 193 (Second Circuit, 2009)
Gao v. Barr
968 F.3d 137 (Second Circuit, 2020)
Singh v. Garland
6 F.4th 418 (Second Circuit, 2021)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Y.C. v. Holder
741 F.3d 324 (Second Circuit, 2013)

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