Aziz Abdurakhmanov v. Eric Holder, Jr., 666 F.3d 978

Abdurakhmanov, Uzbek citizen of Dungan ethnicity, sues for asylum, withholding, and CAT relief based on alleged ethnic persecution in Uzbekistan.
He and his wife were allegedly subjected to police abuse and discrimination as members of the Dungan minority.
In 1999 he was arrested and beaten for three days after an assassination attempt; he claims the arrest was due to ethnicity.
His wife, Yelena, was detained, beaten, and allegedly sexually assaulted in 2000; she died shortly after from head trauma.
Abdurakhmanov sought asylum in the U.S. in 2002 and repeatedly thereafter; the IJ denied relief, later affirmed by the BIA.
The Sixth Circuit ultimately dismisses the petition for review due to one sustained credibility finding and lack of corroboration, notwithstanding some errors in the agency’s handling of corroboration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the adverse credibility finding is supported by substantial evidence	Abdurakhmanov argues inconsistencies do not go to heart of claim.	Agency found discrepancies went to the core of his asylum claim.	Some credibility grounds lack substantial support; at least one remains supported.
Whether the agency properly weighed corroborating evidence	Documents were contemporaneous copies and should be credited.	Documents were not contemporaneous/originals and thus deserve limited weight.	Remand not required; the court reversed on some corroboration grounds and upheld essential credibility issue.
Whether the corpus of corroborating evidence was improperly discounted under Matter of H-L-H-	H-L-H- did not apply; documents still probative as past-event records.	H-L-H- supports deeming materials of limited weight.	Agency error identified; H-L-H- cannot justify disregarding Abdurakhmanov’s corroboration.

Lin v. Holder, 565 F.3d 971 (6th Cir. 2009) (corroboration require reasonable availability of corroborating evidence)
Ramaj v. Gonzales, 466 F.3d 520 (6th Cir. 2006) (authentication standards for documents; not always require originals)
Matter of H-L-H-, 25 I&N Dec. 209 (BIA 2010) (weight of documents obtained for hearing; contemporaneity not always required)
Koulibaly v. Mukasey, 541 F.3d 613 (6th Cir. 2008) (minor inconsistencies cannot always go to heart of claim)
Ceraj v. Mukasey, 511 F.3d 583 (6th Cir. 2007) (credibility must address issues at heart of claim; not all inconsistencies are fatal)
Yu v. Ashcroft, 364 F.3d 700 (6th Cir. 2004) (credibility determinations reviewed for substantial evidence)
Khalili v. Holder, 557 F.3d 429 (6th Cir. 2009) (administrative findings reviewed for substantial evidence; law reviewed de novo)
El-Moussa v. Holder, 569 F.3d 250 (6th Cir. 2009) (heart-of-the-claim credibility impacts burden of proof)
Cruz-Samayoa v. Holder, 607 F.3d 1145 (6th Cir. 2010) (two-step asylum framework and standard for review)