Xin He v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedMay 5, 2025
Docket22-6471 (L)
StatusUnpublished

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

Opinion

22-6471 (L) Xin He v. Bondi BIA Pierro, IJ A205 046 259

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 5th day of May, two thousand twenty- five.

PRESENT: REENA RAGGI, EUNICE C. LEE, MARIA ARAÚJO KAHN, Circuit Judges. _____________________________________

XIN HE, Petitioner,

v. 22-6471 (L), 23-6367 (Con) NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Theodore N. Cox, Esq., New York, NY. FOR RESPONDENT: Brian M. Boynton, Principal Deputy Assistant Attorney General; Linda S. Wernery, Assistant Director; Thankful T. Vanderstar, Senior Trial Attorney, Office of Immigration Litigation, United States Department of Justice, Washington, DC.

UPON DUE CONSIDERATION of these petitions for review of Board of

Immigration Appeals (“BIA”) decisions, it is hereby ORDERED, ADJUDGED,

AND DECREED that the petitions for review are DENIED.

Petitioner Xin He, a native and citizen of the People’s Republic of China,

seeks review of two decisions of the BIA: (1) a September 14, 2022 decision

affirming a decision of an Immigration Judge (“IJ”) finding her removable and

concluding that she had filed a frivolous asylum application, In re Xin He, No. A

205 046 259 (B.I.A. Sept. 14, 2022), aff’g No. A 205 046 259 (Immigr. Ct. N.Y.C. Dec.

30, 2019 & Jan. 27, 2020); and (2) an April 10, 2023 decision denying her motion for

reconsideration, In re Xin He, No. A 205 046 259 (B.I.A. Apr. 10, 2023). We assume

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

As to removability and the frivolous finding, we have reviewed the IJ’s

decision as modified and supplemented by the BIA. 1 See Xue Hong Yang v. U.S.

1The BIA found sufficient grounds, independent of demeanor, to affirm the IJ’s decision. Thus, Xin He could not demonstrate prejudice from alleged bias expressed through the IJ’s demeanor 2 Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005); Yan Chen v. Gonzales, 417 F.3d 268,

271 (2d Cir. 2005). We review “de novo questions of law and the application of

law to fact,” and we review “the agency’s factual findings, including adverse

credibility findings, under the substantial evidence standard.” Hong Fei Gao v.

Sessions, 891 F.3d 67, 76 (2d Cir. 2018); see also Zerrei v. Gonzales, 471 F.3d 342, 345

(2d Cir. 2006) (reviewing removability finding for substantial evidence). The

agency’s factual findings are “conclusive unless any reasonable adjudicator would

be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B).

We review the BIA’s denial of a motion to reconsider for abuse of discretion,

which “may be found where the BIA’s decision provides no rational explanation,

inexplicably departs from established policies, is devoid of any reasoning, or

contains only summary or conclusory statements; that is to say, where the Board

has acted in an arbitrary or capricious manner.” Jin Ming Liu v. Gonzales, 439 F.3d

109, 111 (2d Cir. 2006) (internal quotation marks omitted)).

I. Removability

The Department of Homeland Security (“DHS”) charged Xin He as

findings. Additionally, because the BIA declined to rely on those findings, the Government’s reliance on that portion of the IJ’s decision is misplaced. See Xue Hong Yang, 426 F.3d at 522. 3 removable under 8 U.S.C. § 1227(a)(1)(A), which provides that an “alien who at

the time of . . . adjustment of status was within one or more of the classes of aliens

inadmissible by the law existing at such time is deportable.” DHS alleged that

Xin He was inadmissible at the time of adjustment because she had obtained

asylum “by fraud or willfully misrepresenting a material fact.” 8 U.S.C.

§ 1182(a)(6)(C)(i). DHS then “ha[d] the burden of establishing by clear and

convincing evidence” that Xin He was deportable. Id. § 1229a(c)(3)(A). “No

decision on deportability shall be valid unless it is based upon reasonable,

substantial, and probative evidence.” Id. We uphold a removability finding

unless “any rational trier of fact would be compelled to conclude that the proof

did not rise to the level of clear and convincing evidence.” Francis v. Gonzales, 442

F.3d 131, 138–39 (2d Cir. 2006).

The agency had sufficient basis to conclude that DHS satisfied its burden to

show that the claim in Xin He’s asylum application was false, and that she willfully

made the false statements, given evidence that (1) attorney John Wang prepared

her application and then pleaded guilty to conspiracy to submit fraudulent asylum

applications during the same period, (2) Xin He’s written statement closely

matched statements submitted on behalf of Wang’s other clients, and was written

4 in a manner that contradicted her claim that she wrote the statement herself,

(3) Xin He’s application to adjust to permanent resident status contradicted one

prior allegation regarding past persecution, and (4) Xin He returned to China

shortly after adjusting status despite her alleged fear of persecution.

As a preliminary matter, contrary to Xin He’s argument, circumstantial

evidence is not categorically incapable of satisfying a “clear and convincing”

standard. See United States v. Zhong, 26 F.4th 536, 559 (2d Cir. 2022) (observing

that the standard for a criminal conviction “may be satisfied by circumstantial

evidence alone” (internal quotation marks omitted)); California ex rel. Cooper v.

Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (explaining that the “clear

and convincing” standard is lower than the “beyond a reasonable doubt” standard

for a criminal conviction (internal quotation marks omitted)).

We have held that special caution is required when relying on similarities

between statements in different proceedings, and that the agency should consider,

among other things, “whether the seemingly similar affidavits might merely have

been translated or recorded inaccurately or formulaically,” and “whether there is

a likelihood that the petitioner was an innocent ‘plagiaree.’” Mei Chai Ye v. U.S.

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