Singh v. United States Immigration & Naturalization Service

965 F. Supp. 724, 1997 U.S. Dist. LEXIS 7526, 1997 WL 291858
CourtDistrict Court, D. Maryland
DecidedMay 27, 1997
DocketCivil No. PJM 95-2149
StatusPublished
Cited by1 cases

This text of 965 F. Supp. 724 (Singh v. United States Immigration & Naturalization Service) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Singh v. United States Immigration & Naturalization Service, 965 F. Supp. 724, 1997 U.S. Dist. LEXIS 7526, 1997 WL 291858 (D. Md. 1997).

Opinion

OPINION

MESSITTE, District Judge.

I.

Kunden Singh is being held at the Wicomico County Detention Center in Salisbury, Maryland, awaiting deportation from the United States after the Immigration and Naturalization Service (INS) found him ex-cludable under 8 U.S.C. § 1182(a)(7)(A)(i)(I) (West Supp.1996).1 He has filed a Petition for a Writ of Habeas Corpus in this Court. The Court referred the matter to Magistrate Judge William L. Connelly for a Report and Recommendation. Judge Connelly recommends that the Petition be denied. Having conducted a de novo review of the Petition pursuant to Fed.R.Civ.P. 72(b), see also Camby v. Davis, 718 F.2d 198, 199-200 (4th [727]*727Cir.1983), the Court agrees that the writ should be denied.

II.

The procedural history of this case is undisputed. Singh left India and arrived at Washington-Dulles Airport on a Lufthansa Airlines flight from Germany on May 29, 1994. He presented no valid identification or travel documents and was denied entry into this country. Pending a hearing before an Immigration Judge (IJ), he was detained.

From the outset, Singh admitted that he was properly excludable, but asked the INS to grant him political asylum. As required by law, the INS treated his application as one for both asylum and for withholding of deportation. See 8 U.S.C. § 1253(h) and 8 C.F.R. § 208.3(b). At the close of the INS hearing, the IJ determined that Singh had failed to establish his entitlement to either asylum or the withholding of deportation and he was ordered excluded and deported from the United States.

Singh appealed the IJ’s ruling to the Board of Immigration Appeals (BIA) which, on November 22, 1994, in a de novo opinion, denied the appeal. The Board concluded that any persecution Singh faced in India was not on account of any ground protected by the Immigration and Nationality Act. 8 U.S.C. 1101(a)(42)(A). Singh took no direct appeal from this final administrative order.

Since then the INS has made efforts to return Singh to India, but has been unable to obtain necessary travel documents from the Indian government. The effort of the INS to return Singh to Germany has likewise been unsuccessful. When sent to Germany in January, 19952, Singh left the sterile transit area of the airport and applied for asylum in Germany. Although the German authorities pursued his application, they ultimately denied it and returned him to the United States. He has remained in INS custody since his return.

On July 24, 1995, Singh filed his application for a writ of habeas corpus.3

III.

At the time of his attempted entry, Singh was approximately 22 years of age. He is a native and citizen of India, a Sikh from the State of Punjab. He was never politically active there and experienced no difficulties with the Indian authorities prior to March, 1994. During that month, he was approached by eight armed individuals wearing turbans, apparently Sikh militants. He testified that he was forced, upon threat of death, to drive -these men on a trip, then learned when he returned to his family home that his contact with these militants had come to the attention of the security forces. These forces had arrested his father and brother who were questioned about him. The father and brother were physically mistreated and not long after a bribe secured their release from custody, Singh’s father died in the hospital.

Singh fled to relatives several hundred miles away and was arrested by security forces in late March and held for four days. He was questioned about the militants and beaten.4 After he arranged for a bribe to obtain his release, he sought medical attention for his injuries. Singh testified that he [728]*728knew of other Sikhs who had been abused as he had. In May, 1994, his family arranged for him to depart India.

IV.

Singh challenges the conclusion of the BIA that he is not eligible for asylum, arguing that the Indian authorities imputed a political opinion to him and punished him for that opinion. He also contends that he was not required to show country-wide persecution in view of the fact that the Indian government was the persecutor. Secondarily, he argues that he should be paroled from his current detention because its indefinite duration violates the Due Process Clause of the Constitution. The INS disputes these propositions.

The key threshold issue is what standard or standards of review should be applied.

Neither party suggests that a different standard applies when the challenge to a BIA decision asserted by way of habeas corpus as opposed to direct appeal, although arguably there may be a difference. See Sarkis v. Nelson, 585 F.Supp. 235 (E.D.N.Y.1984), habeas corpus proceeding, 599 F.Supp. 724 (E.D.N.Y.1984). But assuming that the standard of review by way of habeas is the same as that on direct review, the parties still divide over what it is. Singh contends that because the IJ found that he was credible but ineligible for asylum and the BIA adopted that finding, only issues of law are involved. In support of his position, he cites Tarvand v. INS, 937 F.2d 973, 975 (4th Cir.1991). The INS responds that the de novo standard of review does not apply, that the proper standard is the deferential “substantial evidence test.” INS also cites Tarvand, as well as, among other cases, Cruz-Lopez v. INS, 802 F.2d 1518, 1519 n. 1 (4th Cir.1986).

The INS is correct. Singh miscites Tarvand, which states that “[i]n deportation proceedings, we [the appellate court] review credibility and factual findings under the substantial evidence standard but subject mixed questions of law and fact to de novo review.” 937 F.2d at 975, citing Figeroa v. INS, 886 F.2d 76, 78 (4th Cir.1989). The court then specifically noted that “[w]e review the BIA’s decision on a request for withholding of deportation under the substantial evidence standard.” Id. Huaman-Comelio v. Board of Immigration Appeals, 979 F.2d 995, 999 (4th Cir.1992), confirms the applicability of the substantial evidence test. Indeed, under INS v. Elias-Zacarias, 502 U.S. 478, 112 S.Ct.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Haddam v. Reno
54 F. Supp. 2d 602 (E.D. Virginia, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
965 F. Supp. 724, 1997 U.S. Dist. LEXIS 7526, 1997 WL 291858, Counsel Stack Legal Research, https://law.counselstack.com/opinion/singh-v-united-states-immigration-naturalization-service-mdd-1997.