Wei v. McHenry

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 29, 2025
Docket22-6237
StatusUnpublished

This text of Wei v. McHenry (Wei 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
Wei v. McHenry, (2d Cir. 2025).

Opinion

22-6237 Wei v. McHenry BIA Palmer, IJ A208 605 285 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 29th day of January, two thousand twenty-five.

PRESENT: PIERRE N. LEVAL, GERARD E. LYNCH, STEVEN J. MENASHI, Circuit Judges. _____________________________________

LIANG QING WEI, Petitioner,

v. 22-6237 NAC JAMES R. MCHENRY III, ACTING UNITED STATES ATTORNEY GENERAL, Respondent.* _____________________________________

*Pursuant to Federal Rule of Appellate Procedure 43(c)(2), Acting Attorney General James R. McHenry III is automatically substituted for former Attorney General Merrick B. Garland as Respondent. FOR PETITIONER: David Garth Sullivan, Esq., Demidchik Law Firm, PLLC, Flushing, NY.

FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Stephen J. Flynn, Assistant Director; Lynda A. Do, 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 Liang Qing Wei, a native and citizen of the People’s Republic of

China, seeks review of an April 18, 2022, decision of the BIA affirming a May 3,

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

and withholding of removal. 1 In re Liang Qing Wei, No. A208 605 285 (B.I.A. Apr.

18, 2002), aff’g No. A208 605 285 (Immig. Ct. N.Y.C. May 3, 2019). We assume the

parties’ familiarity with the underlying facts and procedural history.

Under the circumstances, we have reviewed the IJ’s decision as

supplemented by the BIA. See Chen v. Garland, 75 F.4th 109, 112 (2d Cir. 2023).

1 Wei did not assert a claim for protection under the Convention Against Torture on appeal to the BIA or in his brief here.

2 We review factual findings for substantial evidence and questions of law and

application of law to fact de novo. See Bhagtana v. Garland, 93 F.4th 592, 594 (2d

Cir. 2023). “[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).

An applicant for asylum must establish past persecution or a well-founded

fear of persecution on account of a protected ground. 8 U.S.C. §§ 1101(a)(42)(A),

1158(b)(1)(B)(i). Wei asserted that family planning officials forced his wife to

undergo sterilization and fined them after the birth of their second child in the

1990s, and that government officials physically attacked and sought to arrest him

in 2014 for opposing government corruption in the exercise of eminent domain

powers. The agency did not err in finding that Wei failed to satisfy his burden of

establishing that the harm he suffered rose to the level of persecution or that his

fear of future persecution is well-founded.

“Persecution is an extreme concept that does not include every sort of

treatment our society regards as offensive.” Mei Fun Wong v. Holder, 633 F.3d 64,

72 (2d Cir. 2011) (quotation marks omitted). A valid claim of past persecution

may “encompass[] a variety of forms of adverse treatment, including non-life-

3 threatening violence and physical abuse,” but the harm must be sufficiently

severe, rising above “mere harassment.” Ivanishvili v. U.S. Dep’t of Just., 433 F.3d

332, 341 (2d Cir. 2006) (quotation marks and brackets omitted). “‘[T]he difference

between harassment and persecution is necessarily one of degree,’ [and] the

degree must be assessed with regard to the context in which the mistreatment

occurs.” Beskovic v. Gonzales, 467 F.3d 223, 226 (2d Cir. 2006) (citation omitted)

(quoting Ivanishvili, 433 F.3d at 341). “[W]hile a severe fine can amount to

economic persecution, an alien claiming to have suffered past persecution must

show more than the imposition of such a fine; he must show that payment of the

fine (or efforts to pay or collect it) actually deprived him of the basic necessities of

life or reduced him to an impoverished existence.” Huo Qiang Chen v. Holder, 773

F.3d 396, 400 (2d Cir. 2014).

Absent past persecution, an applicant may establish eligibility for asylum

by demonstrating a well-founded fear of future persecution based on “a

reasonable possibility of suffering such persecution if he or she were to return to

that country.” 8 C.F.R. § 1208.13(b)(2)(i)(B). To demonstrate that reasonable

possibility, an applicant must show either that he would be “singled out

individually for persecution” or that the country of removal has a “pattern or

4 practice” of persecuting “similarly situated” individuals. Id. § 1208.13(b)(2)(iii).

Wei was not eligible for asylum based on his wife’s forced sterilization. See

Shi Liang Lin v. U.S. Dep’t of Just., 494 F.3d 296, 309–10 (2d Cir. 2007). To qualify

for asylum, Wei was required to demonstrate that (1) he engaged in “other

resistance” to the family planning policy, and (2) he suffered harm rising to the

level of persecution or had a well-founded fear of suffering such harm as a direct

result of his resistance. 8 U.S.C. § 1101(a)(42); see Shi Liang Lin, 494 F.3d at 313;

Matter of J-S-, 24 I. & N. Dec. 520, 523 (A.G. 2008).

Assuming that Wei was targeted for resisting the family planning policy,

the agency did not err in finding that he failed to demonstrate that he suffered

persecution as a result because he did not testify that family planning officials

caused him to personally suffer severe physical, emotional, or economic harm.

See Mei Fun Wong, 633 F.3d at 72; Ivanishvili, 433 F.3d at 341; Huo Qiang Chen, 773

F.3d at 400. Wei did not assert a fear of future harm under the family planning

policy, admitting that family planning officials had not interacted with him or his

wife between 1998, when his wife was sterilized, and when they left China in 2019.

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Jian Qiu Liu v. Holder
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633 F.3d 64 (Second Circuit, 2011)
Shi Liang Lin v. United States Department of Justice
494 F.3d 296 (Second Circuit, 2007)
Huo Qiang Chen v. Holder
773 F.3d 396 (Second Circuit, 2014)
J-S
24 I. & N. Dec. 520 (Board of Immigration Appeals, 2008)
FEDORENKO
19 I. & N. Dec. 57 (Board of Immigration Appeals, 1984)
Beskovic v. Gonzales
467 F.3d 223 (Second Circuit, 2006)
Chen v. Garland
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Singh Bhagtana v. Garland
93 F.4th 592 (Second Circuit, 2023)

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