Angelina Domingo-Mateo v. Merrick B. Garland, 20-4263

Petitioners: Angelina Domingo‑Mateo (Guatemalan) and her six‑year‑old son sought asylum and withholding of removal based on gang extortion threats tied to a cousin who sent her money.
Proceedings: DHS issued a Notice to Appear (May 2015); multiple master hearings used Kanjobal or Spanish interpreters; individual hearing (Sept. 28, 2018) used a Kanjobal interpreter while petitioner’s stated best language is Akateko.
At the individual hearing the IJ repeatedly instructed Domingo‑Mateo to answer more directly (often yes/no); counsel expressed concern about the interpreter but the IJ relied on an earlier confirmation that the parties understood one another and discouraged challenging the interpreter.
IJ’s merits finding: denied asylum/withholding because petitioners failed to show past persecution or nexus (masked men did not threaten, no clear link to cousin, six family members safe in Guatemala, no police report).
BIA affirmed; petitioners filed for review alleging due‑process violations: (1) incompetent interpreter and (2) IJ bias/hostility.
Sixth Circuit denied the petition, holding no due‑process violation: petitioners failed to show prejudice from the interpreter and the IJ’s demeanor did not constitute unconstitutional bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competent interpreter (due process)	Domingo‑Mateo: interpreter spoke Kanjobal not petitioner’s Akateko dialect; interpreter confirmation and oath were inadequate; counsel discouraged from probing — hearing was not full and fair	Government: interpreter use and confirmations were sufficient; petitioner did not show that any translation error affected the IJ’s findings	Held: No due‑process violation — petitioner failed to show prejudice linking alleged translation problems to the IJ’s fact‑based denial of past persecution
IJ bias/hostility (due process)	Domingo‑Mateo: IJ’s repeated admonitions, limiting testimony to yes/no, and reprimands showed hostility and prejudgment	Government: IJ acted within quasi‑judicial control of hearing to obtain clear, relevant testimony; impatience does not equal bias	Held: No due‑process violation — IJ’s tone aimed at clarity and did not show partisan adjudication or require reversal

Amadou v. I.N.S., 226 F.3d 724 (6th Cir. 2000) (recognizes due‑process right to a full and fair hearing and a competent interpreter)
Ahmed v. Gonzales, 398 F.3d 722 (6th Cir. 2005) (de novo review for due‑process claims in removal proceedings)
Ivezaj v. I.N.S., 84 F.3d 215 (6th Cir. 1996) (IJs have authority to control hearing pace and require focused, relevant testimony)
Liteky v. United States, 510 U.S. 540 (1994) (expressions of impatience or anger do not by themselves show judicial bias)
Hassan v. Gonzales, 403 F.3d 429 (6th Cir. 2005) (admonitory language by IJ does not necessarily amount to partisan adjudication)
Garza‑Moreno v. Gonzales, 489 F.3d 239 (6th Cir. 2007) (to prevail on bias claim, petitioner must show both error and substantial prejudice)
Reyes‑Melendez v. I.N.S., 342 F.3d 1001 (9th Cir. 2003) (discusses limits of IJ conduct that could intimidate parties)