Jiang-Zhao v. McHenry

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 4, 2025
Docket23-6162
StatusUnpublished

This text of Jiang-Zhao v. McHenry (Jiang-Zhao v. McHenry) 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
Jiang-Zhao v. McHenry, (2d Cir. 2025).

Opinion

23-6162 Jiang-Zhao v. McHenry BIA Poczter, IJ A209 285 378

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.

1 At a stated term of the United States Court of Appeals for the Second 2 Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley 3 Square, in the City of New York, on the 4th day of February, two thousand 4 twenty-five. 5 6 PRESENT: 7 PIERRE N. LEVAL, 8 MICHAEL H. PARK, 9 ALISON J. NATHAN, 10 Circuit Judges. 11 _____________________________________ 12 13 HAO JIE JIANG-ZHAO, 14 Petitioner, 15 16 v. 23-6162 17 NAC 18 JAMES R. MCHENRY, III, ACTING 19 UNITED STATES ATTORNEY 20 GENERAL, 21 22 Respondent. 23 _____________________________________ 1 2 FOR PETITIONER: Thomas V. Massucci, Esq., New York, NY. 3 FOR RESPONDENT: Brian M. Boynton, Principal Deputy Assistant 4 Attorney General; Jonathan A. Robbins, 5 Assistant Director; Zoe J. Heller, Senior 6 Litigation Counsel, Office of Immigration 7 Litigation, United States Department of 8 Justice, Washington, DC.

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

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

11 DECREED that the petition for review is DENIED.

12 Petitioner Hao Jie Jiang-Zhao, a native and citizen of the People’s Republic

13 of China, seeks review of a January 27, 2023, decision of the BIA affirming a June

14 5, 2019, decision of an Immigration Judge (“IJ”) denying his application for

15 asylum, withholding of removal, and relief under the Convention Against Torture

16 (“CAT”) and concluding that Jiang-Zhao filed a frivolous asylum application. In

17 re Hao Jie Jiang-Zhao, No. A 209 285 378 (B.I.A. Jan. 27, 2023), aff’g No. A 209 285 378

18 (Immig. Ct. N.Y. City June 5, 2019). We assume the parties’ familiarity with the

19 underlying facts and procedural history.

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

21 Dep’t of Homeland Sec., 448 F.3d 524, 528 (2d Cir. 2006). We review the agency’s

22 factual findings under the substantial evidence standard, and we review questions 2 1 of law de novo. See Yanqin Weng v. Holder, 562 F.3d 510, 513 (2d Cir. 2009).

2 “[T]he administrative findings of fact are conclusive unless any reasonable

3 adjudicator would be compelled to conclude to the contrary.” 8 U.S.C.

4 § 1252(b)(4)(B).

5 Jiang-Zhao challenges only the agency’s conclusion that he filed a frivolous

6 asylum application. “If the Attorney General determines that an alien has

7 knowingly made a frivolous application for asylum and the alien has received

8 notice [of the consequences] . . . , the alien shall be permanently ineligible for” most

9 immigration relief. 8 U.S.C. § 1158(d)(6); see also id. § 1158(d)(4)(A); 8 C.F.R.

10 § 1208.20; 1 Niang v. Holder, 762 F.3d 251, 253 (2d Cir. 2014) (“A person who makes

11 an application for asylum determined to be frivolous, or deliberately and

12 materially false, is subject to a grave penalty: permanent ineligibility for most

13 forms of relief under the immigration laws.” (quoting Mei Juan Zheng v. Mukasey,

14 514 F.3d 176, 178 (2d Cir. 2008))). An asylum application is “frivolous if any of its

15 material elements is deliberately fabricated.” 8 C.F.R. § 1208.20. The BIA has set

16 forth four procedural safeguards that an IJ must follow in rendering frivolousness

1 Citations to 8 C.F.R. § 1208.20 are to the version in effect at the time Jiang-Zhao filed his asylum application in 2017. See Ud Din v. Garland, 72 F.4th 411, 424 n.3 (2d Cir. 2023) (discussing applicability of amendments to regulations). 3 1 findings:

2 (1) notice to the alien of the consequences of filing a frivolous 3 application; (2) a specific finding by the Immigration Judge or the 4 Board that the alien knowingly filed a frivolous application; (3) 5 sufficient evidence in the record to support the finding that a material 6 element of the asylum application was deliberately fabricated; and (4) 7 an indication that the alien has been afforded sufficient opportunity 8 to account for any discrepancies or implausible aspects of the claim. 9 10 Biao Yang v. Gonzales, 496 F.3d 268, 275 (2d Cir. 2007) (quoting Matter of Y-L-, 24 I.

11 & N. Dec. 151, 155 (B.I.A. 2007)); see also 8 U.S.C. § 1158(d)(4)(A) (requiring notice

12 of consequences of filing frivolous application).

13 Jiang-Zhao does not contest that he received notice of the consequences of

14 filing a frivolous claim or challenge the specificity of the agency’s finding.

15 Accordingly, the only issues are whether he fabricated a material element and was

16 provided an opportunity to explain.

17 The agency reasonably concluded that Jiang-Zhao knowingly filed a

18 frivolous asylum application and that a material element of his application was

19 deliberately fabricated. See 8 C.F.R. § 1208.20; Matter of Y-L-, 24 I. & N. Dec. at 156

20 (“[A]n Immigration Judge’s specific finding that a respondent deliberately

21 fabricated a material element of his asylum claim constitutes a finding that he

22 knowingly filed a frivolous asylum application.”). Jiang-Zhao concedes that his

4 1 detention is a material aspect of his claim, but reiterates his explanation, rejected

2 by the agency, that his parents used a connection and paid a bribe to bail him out

3 for one day to receive medical care and go to the consulate. He argues that the

4 record does not support a finding of deliberate fabrication, but only reflects an

5 omission of this fact from his application. The IJ reasonably concluded that his

6 explanation was implausible, meaning that he fabricated his detention because he

7 could not have been detained in Fujian Province and at the consulate in another

8 province at the same time. See Siewe v. Gonzales, 480 F.3d 160, 169 (2d Cir. 2007)

9 (“So long as an inferential leap is tethered to the evidentiary record, we will accord

10 deference to the finding.”); Majidi v.

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Related

Biao Yang v. Gonzales
496 F.3d 268 (Second Circuit, 2007)
Weng v. Holder
562 F.3d 510 (Second Circuit, 2009)
Mei Juan Zheng v. Mukasey
514 F.3d 176 (Second Circuit, 2008)
Niang v. Holder
762 F.3d 251 (Second Circuit, 2014)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Ud Din v. Garland
72 F.4th 411 (Second Circuit, 2023)

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