Li v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedAugust 19, 2025
Docket23-7141
StatusUnpublished

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

Opinion

23-7141 Li v. Bondi BIA McKee, IJ A206 890 750

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 19th day of August, two thousand twenty-five.

PRESENT: JOHN M. WALKER, JR., RICHARD J. SULLIVAN, MYRNA PÉREZ, Circuit Judges. _____________________________________

JIANCHUAN LI, Petitioner,

v. 23-7141 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Troy Nader Moslemi, Esq., Flushing, NY. FOR RESPONDENT: Brian M. Boynton, Principal Deputy Assistant Attorney General; John S. Hogan, Assistant Director; Todd J. Cochran, Senior 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 Jianchuan Li, a native and citizen of the People’s Republic of

China, seeks review of an August 25, 2023, decision of the BIA affirming a March

22, 2022, decision of an Immigration Judge (“IJ”) denying his application for

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

(“CAT”). In re Jianchuan Li, No. A 206 890 750 (B.I.A. Aug. 25, 2023), aff’g No. A

206 890 750 (Immigr. Ct. N.Y.C. Mar. 22, 2022). We assume the parties’ familiarity

with the underlying facts and procedural history.

We have considered the IJ’s decision as modified by the BIA, i.e., minus the

findings the BIA declined to reach regarding Li’s use of a smuggler or the name of

his pastor. See Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005).

“We review the agency’s factual findings, including adverse credibility findings,

under the substantial evidence standard,” and we review “questions of law and 2 the application of law to fact” de novo. 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.” 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. Here, we find that substantial evidence supports the agency’s

adverse credibility determination given the inconsistencies between Li’s oral

3 testimony and his supporting documentation as to: (1) whose home he was in

when he was arrested; (2) whether he required surgery; and (3) whether he

complied with the requirement that he report to the police. 1 See 8 U.S.C.

§ 1158(b)(1)(B)(iii); 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.”).

First, Li was inconsistent as to whose home he visited for church on the day

of his arrest. In his written application, Li reported that he was at “Huang

Daming’s house.” Cert. Admin. R. at 382. At the hearing, however, he testified

on direct that the gathering was at the home of “Huang Da Peng.” Id. at 94. And

then on cross-examination he said that it was “held in the home of Chen Yuen.”

Id. at 108. When asked to clarify, he alternated between saying that the gathering

was at the home of “Huang Da Peng” and “Chen Yuen.” See id. at 107–10, 114–

1Although Li did not challenge these findings before the BIA, we consider him to have generally exhausted review of the adverse credibility determination except as specifically addressed because the BIA affirmed the adverse credibility determination, it did not explicitly find that he waived review of that determination, and the government does not invoke exhaustion except as to discrete issues. See Santos-Zacaria v. Garland, 598 U.S. 411, 423 (2023) (concluding that exhaustion is a non-jurisdictional claim-processing rule “subject to waiver and forfeiture”). 4 15. In his petition, Li acknowledges these inconsistencies, but argues that

“Huang Da Ming” and “Huang Da Peng” are similar sounding names, rendering

the inconsistency trivial. However, he does not address the inconsistency as to

“Chen Yuen” and, as the government argues, his explanation that the first two

names were similar is unexhausted because he did not raise it before the agency.

See 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.”).

Second, the record is inconsistent as to the injuries Li suffered in detention.

Li testified that his thumb was broken, that he was hospitalized for one month,

and that he had surgery on his thumb. But he gave conflicting testimony as to

whether his thumb was bleeding , and none of the medical records provided by Li

mentioned surgery. Li’s wife’s letter was also inconsistent with his testimony, as

the letter stated that “his hand was . . . bleeding” from the injuries he sustained,

Cert. Admin. R. at 198, though Li ultimately confirmed that his thumb was not

bleeding, id. at 121. See Xiu Xia Lin, 534 F.3d at 167 (relying in part on omissions

in third-party letters as to facts “not directly material” to petitioner’s claim to

support an adverse credibility determination). Apart from Li’s failure to “offer

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Related

Xiu Xia Lin v. Mukasey
534 F.3d 162 (Second Circuit, 2008)
Gao v. Sessions
891 F.3d 67 (Second Circuit, 2018)
Santos-Zacaria v. Garland
598 U.S. 411 (Supreme Court, 2023)

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Li v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/li-v-bondi-ca2-2025.