Nkezea Efuetnji v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedMay 9, 2025
Docket23-6129
StatusUnpublished

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

Opinion

23-6129 Nkezea Efuetnji v. Bondi BIA Baumgarten, IJ A240 739 843

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 9th day of May, two thousand twenty- 4 five. 5 6 PRESENT: 7 REENA RAGGI, 8 STEVEN J. MENASHI, 9 MARIA ARAÚJO KAHN, 10 Circuit Judges. 11 _____________________________________ 12 13 NKEZEA EFUETNJI, 14 Petitioner, 15 16 v. 23-6129 17 NAC 18 PAMELA BONDI, UNITED STATES 19 ATTORNEY GENERAL, 20 Respondent. 21 _____________________________________ 22 23 FOR PETITIONER: Rajan O. Dhungana, Esq., Anaheim, CA. 1 FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant 2 Attorney General; Anthony P. Nicastro, 3 Assistant Director; Yanal H. Yousef, Trial 4 Attorney, Office of Immigration Litigation, 5 United States Department of Justice, 6 Washington, DC.

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

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

9 DECREED that the petition for review is DENIED.

10 Petitioner Nkezea Efuetnji, a native and citizen of Cameroon, seeks review

11 of a BIA decision summarily affirming an Immigration Judge’s (“IJ”) denial of his

12 application for asylum, withholding of removal, and relief under the Convention

13 Against Torture (“CAT”). In re Nkezea Efuetnji, No. A 240 739 843 (B.I.A. Jan. 11,

14 2023), aff’g No. A 240 739 843 (Immig. Ct. Buffalo Sept. 13, 2022). We assume the

15 parties’ familiarity with the underlying facts and procedural history.

16 Because the BIA affirmed the IJ’s decision without opinion, we review the

17 IJ’s decision as the final agency determination. See Shunfu Li v. Mukasey, 529 F.3d

18 141, 146 (2d Cir. 2008). We review fact-finding, including an adverse credibility

19 determination, “under the substantial evidence standard,” and we review

20 questions of law and the application of law to fact de novo. Hong Fei Gao v. Sessions,

21 891 F.3d 67, 76 (2d Cir. 2018). “[T]he administrative findings of fact are conclusive 2 1 unless any reasonable adjudicator would be compelled to conclude to the

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

3 As an initial matter, Efuetnji’s contentions on appeal—that the agency

4 misapplied Fifth Circuit case law and that his due process right to counsel was

5 violated—are unexhausted because he did not raise them before the BIA. While

6 issue exhaustion is “not jurisdictional,” Santos-Zacaria v. Garland, 598 U.S. 411, 431

7 (2023), it is mandatory when, as here, the Government raises it, see Ud Din v.

8 Garland, 72 F.4th 411, 419–20 & n.2 (2d Cir. 2023). We will not consider these

9 arguments. See Punin v. Garland, 108 F.4th 114, 124 (2d Cir. 2024) (“[W]hen an

10 argument made to this Court cannot be closely matched up with a specific

11 argument made to the BIA, it has not been properly exhausted and we cannot hear

12 it.”).

13 We find no error in the IJ’s determination that Efuetnji’s testimony was

14 problematic and insufficient to meet his burden, particularly given the lack of

15 corroboration. An asylum applicant has the burden of proof to establish past

16 persecution or a well-founded fear of future persecution. 8 U.S.C.

17 § 1158(b)(1)(B)(i); 8 C.F.R. § 1208.13(a), (b). An applicant’s testimony “may be

18 sufficient to sustain the applicant’s burden without corroboration,” but only if the

3 1 applicant testifies credibly and persuasively. 8 U.S.C. § 1158(b)(1)(B)(ii). “Where

2 the trier of fact determines that the applicant should provide evidence that

3 corroborates otherwise credible testimony, such evidence must be provided unless

4 the applicant does not have the evidence and cannot reasonably obtain the

5 evidence.” Id. “Considering the totality of the circumstances, and all relevant

6 factors, a trier of fact may base a credibility determination on . . . the consistency

7 between the applicant’s or witness’s written and oral statements . . . , the internal

8 consistency of each such statement, [and] the consistency of such statements with

9 other evidence of record . . . without regard to whether an inconsistency,

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

11 relevant factor.” Id. § 1158(b)(1)(B)(iii). “We defer . . . to an IJ’s credibility

12 determination unless . . . it is plain that no reasonable fact-finder could make such

13 an adverse credibility ruling.” Xiu Xia Lin v. Mukasey, 534 F.3d 162, 167 (2d Cir.

14 2008); accord Hong Fei Gao, 891 F.3d at 76.

15 The IJ found Efuetnji not credible for two primary reasons, and each is

16 supported by the record. His testimony was limited, generalized, lacked

17 persuasive detail, and was presented in an almost “formulaic recitation of facts,”

18 leading the IJ to infer that the testimony had been memorized in a “scripted

4 1 fashion.” Certified Administrative Record (“CAR”) at 40–41. Second, a

2 comparison of his written statements and testimony reflected an inconsistency of

3 two years in Efuetnji’s timeline. See id. at 43. When asked on direct examination

4 “[w]here [he] and [his] family live[d] after” his family home burned down in

5 October 2016, Efuetnji responded that “we . . . moved to my aunt’s house in the

6 region called Buea southwest region [of Cameroon]” that same month. Id. at 192.

7 In his written I-589 application for asylum, however, Efuetnji stated that he

8 remained in his home village after his family home burned down and only moved

9 to Buea in June 2018. Id. at 193–94.

10 As to Efuetnji’s vague and seemingly rehearsed testimony, an IJ “may base

11 a credibility determination on the demeanor, candor, or responsiveness of the

12 applicant or witness.” 8 U.S.C. § 1158(b)(1)(B)(iii); Majidi v. Gonzles, 430 F.3d 77,

13 81 n.1 (2d Cir. 2005) (noting that IJ is in best position to determine if applicant “was

14 . . . attempting truthfully to recount what he recalled of key events or struggling

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Nkezea Efuetnji v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nkezea-efuetnji-v-bondi-ca2-2025.