Hussain v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedJune 20, 2025
Docket24-1812
StatusUnpublished

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

Opinion

24-1812 Hussain v. Bondi BIA Reid, IJ A246 913 619/620/621

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 20th day of June, two thousand twenty- five.

PRESENT: RICHARD C. WESLEY, MICHAEL H. PARK, EUNICE C. LEE, Circuit Judges. _____________________________________

MNOWAR HUSSAIN, MST FARHANA AKTHER, A.S., Petitioners,

v. 24-1812 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. ∗

∗ The Clerk of Court is respectfully directed to amend the caption, including to

abbreviate the minor petitioner’s name, as set forth above. _____________________________________

FOR PETITIONERS: Xiaotao Wang, Law Office of Xiaotao Wang, P.C., New York, NY.

FOR RESPONDENT: Yaakov M. Roth, Acting Assistant Attorney General; Vanessa M. Otero, Senior Litigation Counsel; Duncan T. Fulton, 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.

Petitioners Mnowar Hussain, Mst Farhana Akther, and their minor

daughter, natives and citizens of Bangladesh, seek review of a June 6, 2024 decision

of the BIA affirming a September 11, 2023 decision of an Immigration Judge (“IJ”)

denying Hussain’s application for asylum, withholding of removal, and relief

under the Convention Against Torture (“CAT”). In re Mnowar Hussain, et al., Nos.

A 246 913 619/620/621 (B.I.A. June 6, 2024), aff’g Nos. A 246 913 619/620/621

(Immigr. Ct. N.Y.C. Sept. 11, 2023). We assume the parties’ familiarity with the

underlying facts and procedural history.

2 We have reviewed both the IJ’s and BIA’s decisions “for the sake of

completeness.” Wangchuck v. Dep’t of Homeland Sec., 448 F.3d 524, 528 (2d Cir.

2006). We review questions of law de novo and factual findings, including

adverse credibility determinations, for substantial evidence. Hong Fei Gao v.

Sessions, 891 F.3d 67, 76 (2d Cir. 2018). “[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).

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

trier of fact may base a credibility determination on . . . 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.” Id. § 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.”

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

F.3d at 76.

As an initial matter, Hussain has abandoned any challenge to the agency’s

reliance on inconsistencies regarding the name of the person who helped him after

a December 2021 attack and which attack involved a knife by not addressing these

findings in his brief. “We consider abandoned any claims not adequately

presented in an appellant’s brief, and an appellant’s failure to make legal or factual

arguments constitutes abandonment.” Debique v. Garland, 58 F.4th 676, 684 (2d

Cir. 2023) (quotation marks omitted). Although Hussain asserted before the BIA

and in his brief here that he is presenting new evidence to the BIA that would

resolve these inconsistencies, he has not presented such evidence or filed a motion.

Regardless, our review is limited to the administrative record. See 8 U.S.C.

§ 1252(b)(4)(A) (providing that “the court of appeals shall decide the petition only

on the administrative record on which the order of removal is based”).

In any event, substantial evidence supports the agency’s determination that

Hussain did not credibly claim that members of the Awami League (“AL”)

attacked him multiple times due to his membership in the Liberal Democratic

Party (“LDP”). First, the agency reasonably rejected Hussain’s explanation that

4 he did not know the real name of his friend who helped him after the December

2021 attack, particularly because that friend’s affidavit stated that he and Hussain

had known each other “for a long time.” Certified Admin. Record at 541-43.

Second, Hussain’s wife stated that he was attacked with a knife during a June 2022

attack, which contradicted Hussain’s statement and supporting evidence that the

knife was used in an October 2022 attack. Neither Hussain nor his wife offered

any explanation for this inconsistency. Third, Hussain testified that his left knee

was injured in the attack and produced a photograph purporting to show a scar

on his left knee, but his and his father’s written statements and his hospital records

indicated that this injury was to his right knee. The agency was not compelled to

credit Hussain’s conflicting explanations that the written statements were

mistaken, that both knees sustained injuries, and that his “mind [wa]s not

functioning well” and he was not “able to comprehend everything properly.” Id.

at 174; see Majidi v. Gonzales, 430 F.3d 77, 80 (2d Cir. 2005) (“A petitioner must do

more than offer a plausible explanation for his inconsistent statements to secure

relief; he must demonstrate that a reasonable fact-finder would be compelled to

credit his testimony.” (cleaned up)); see also Biao Yang v. Gonzales, 496 F.3d 268, 272

(2d Cir. 2007) (upholding adverse credibility determination when applicant

5 “appeared to be simply making up testimony when confronted by

inconsistencies” (quotation marks omitted)). And contrary to Hussain’s

explanation, there is no evidence that both knees were injured. Certified Admin.

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Related

Biao Yang v. Gonzales
496 F.3d 268 (Second Circuit, 2007)
Mei Chai Ye v. United States Department of Justice
489 F.3d 517 (Second Circuit, 2007)
Xiu Xia Lin v. Mukasey
534 F.3d 162 (Second Circuit, 2008)
Gao v. Barr
968 F.3d 137 (Second Circuit, 2020)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Y.C. v. Holder
741 F.3d 324 (Second Circuit, 2013)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)

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