Bi Qing Zheng v. Loretta Lynch, 819 F.3d 287

Zheng, a Chinese national, entered the U.S. without inspection in 2014 and conceded removability; she applied for asylum, withholding of removal, and CAT protection based on religious persecution (Christianity).
She claimed police in China knew of her Christianity and would arrest/torture her; her son was previously arrested and beaten in China for participating in an underground house church.
At the merits hearing Zheng and four witnesses testified; the record included three nearly identical, undated letters purportedly from Zheng’s sisters and prior visa application documents containing false information.
The IJ found multiple inconsistencies between Zheng’s written application, her credible-fear interview, and hearing testimony (e.g., church membership, knowledge of Christianity, whether her son identified her to police) and noted fraudulent visa applications.
The IJ discounted the sister letters as weak corroboration and made an adverse credibility finding; the BIA affirmed, denying asylum, withholding, and CAT relief. Zheng appealed alleging adverse credibility, insufficiency of corroboration, and due process violations.

Issue	Zheng's Argument	Government's Argument	Held
Adverse credibility determination	Zheng argued her testimony and corroboration were credible and sufficient	DHS argued testimony contained material inconsistencies and fraud that supported adverse credibility	Court upheld adverse credibility; substantial evidence supported IJ/BIA findings
Sufficiency of corroboration (sisters' letters)	Letters corroborate events and detention effects on son; support her claim	DHS and IJ argued letters were unreliable, identical, undated, and not requested by family	Court found letters insufficient corroboration; IJ properly gave them little weight
Impact of fraudulent visa applications	Zheng argued use of visa records was unfair/beyond relevance; alleged DHS withheld records	DHS argued false visa applications impeached credibility and were properly admitted; full record provided	Court held admission permissible and relevant to motive; no prejudice shown, so no due process violation
Due process / IJ bias claim	Zheng claimed IJ was partial and unfair in questioning and evidentiary rulings	DHS said IJ acted within broad discretion and considered all evidence; petitioner not prejudiced	Court found no due process violation; petitioner failed to show prejudice or compelling error

Khalili v. Holder, 557 F.3d 429 (6th Cir. 2009) (standard for reviewing BIA decisions)
Bi Xia Qu v. Holder, 618 F.3d 602 (6th Cir. 2010) (BIA factual findings conclusive unless no reasonable adjudicator could disagree)
Slyusar v. Holder, 740 F.3d 1068 (6th Cir. 2014) (REAL ID Act permits consideration of inconsistencies without regard to whether they go to the heart of the claim)
Parlak v. Holder, 578 F.3d 457 (6th Cir. 2009) (upholding BIA when supported by substantial evidence)
Pilica v. Ashcroft, 388 F.3d 941 (6th Cir. 2004) (discredited testimony, absent corroboration, cannot support CAT relief)
Borovikova v. U.S. Dep’t of Justice, 435 F.3d 151 (2d Cir. 2006) (fraudulent documents may justify adverse credibility finding)
Vasha v. Gonzales, 410 F.3d 863 (6th Cir. 2005) (due process requires impartial adjudicator; IJ must not act as advocate)
Ndrecaj v. Mukasey, 522 F.3d 667 (6th Cir. 2008) (no due-process violation where IJ gave detailed explanation for credibility findings)