Baljinder Cheema v. Eric H. Holder Jr., 2012 U.S. App. LEXIS 18742

Cheema admits he filed a fabricated asylum application supported by fraudulent documents.
The IJ found Cheema knowingly filed a frivolous asylum application under 8 U.S.C. § 1158(d)(6).
Permanent ineligibility for benefits attaches if an applicant knowingly files a frivolous asylum application and receives proper notice under § 1158(d)(4)(A).
The central dispute is whether the written advisals on the standard I-589 form provide adequate notice under § 1158(d)(4)(A).
Cheema signed the I-589 with a bold warning about frivolousness and permanent ineligibility, but did not check the counsel-list box.
Cheema later testified before an asylum officer and acknowledged reading/understanding the form, with a Punjabi interpreter confirming comprehension.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the I-589 advisals satisfy § 1158(d)(4)(A) adequacy.	Cheema argues warnings are inadequate due to form limitations.	Holder argues the written warnings on the form suffice to notify of consequences and counsel right.	Yes; the written advisals are adequate notifications under § 1158(d)(4)(A).

Ribas v. Mukasey, 545 F.3d 922 (10th Cir. 2008) (written asylum-notice sufficiency for frivolousness)
Toj-Culpatan v. Holder, 612 F.3d 1088 (9th Cir. 2010) (form advisals provide requisite notice; per curiam)
Khadka v. Holder, 618 F.3d 996 (9th Cir. 2010) (notice sufficient; discussion of advisals)
Chen v. Mukasey, 527 F.3d 935 (9th Cir. 2008) (discussion on notice and form advisals)
Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (notice on asylum form adequacy noted)
Luciana v. Att’y Gen. of the U.S., 502 F.3d 273 (3d Cir. 2007) (discussion of notice requirements for frivolousness)