Boodhoo v. Sessions, 682 F. App'x 62

Petitioner Oditnarian Boodhoo, a Guyanese national, sought asylum, withholding of removal, and CAT relief after arriving in the U.S.; IJ denied relief and BIA affirmed.
The BIA affirmed an adverse credibility finding by the IJ, which was dispositive of relief.
Key factual disputes: whether Boodhoo filed a police report in Guyana (supported by a cousin’s affidavit), an omitted stop in Trinidad (where he bought a passport), and two uncorroborated threats (a friend’s warning about a gang hit and neighbors reporting armed men at his home).
The IJ questioned Boodhoo’s familiarity with his own corroborating affidavit, noted omissions in his application about travel through Trinidad, and emphasized lack of corroboration from Reve and neighbors.
Boodhoo also sought venue transfer from Buffalo to New York City and later submitted criminal-transcript evidence to the BIA; both requests were denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adverse credibility determination	Boodhoo argued inconsistencies were explainable (nickname, illiteracy) and offered cousin affidavit and other evidence	Government argued inconsistencies, omissions, and lack of corroboration justified disbelief	Court held substantial evidence supported adverse credibility; affirmed denial of relief
Omission of Trinidad stop	Boodhoo downplayed omission or offered explanation about travel	Government relied on the omission as an inconsistency undermining credibility	Court held omission properly considered and supported adverse credibility
Failure to corroborate threats	Boodhoo argued testimony was sufficient; later submitted criminal transcripts to BIA	Government argued central threats lacked corroboration from Reve or neighbors	Court held lack of corroboration supported adverse credibility; criminal transcripts irrelevant to credibility finding
Venue transfer denial	Boodhoo argued transfer would aid presentation of evidence	Government argued transfer not necessary; no prejudice shown	Court held denial not an abuse of discretion and Boodhoo not prejudiced

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir. 2005) (standard for reviewing BIA modifications of IJ decisions)
INS v. Bagamasbad, 429 U.S. 24 (U.S. 1976) (no need to decide issues unnecessary to outcome)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (credibility assessment may consider inconsistencies even if not ‘heart’ of claim)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (petitioner must compel credit by reasonable factfinder; mere plausible explanation insufficient)
Zhou Yun Zhang v. INS, 386 F.3d 66 (2d Cir. 2004) (same principle on credibility explanations)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (failure to corroborate may affect credibility)
Monter v. Gonzales, 430 F.3d 546 (2d Cir. 2005) (remand for venue transfer requires abuse of discretion plus prejudice)
Li Yong Cao v. U.S. Dep’t of Justice, 421 F.3d 149 (2d Cir. 2005) (BIA’s denial to remand for new evidence reviewed for abuse of discretion)