Israel Adamu v. Loretta Lynch, 675 F. App'x 261

Petitioner Israel Gimmuh Adamu, a Cameroonian national, sought asylum, withholding of removal, and CAT protection; the IJ denied relief and the Board of Immigration Appeals dismissed his appeal.
The IJ did not make an adverse credibility finding, so Adamu retained a rebuttable presumption of credibility on appeal.
The agency discounted much of Adamu’s corroborating documentary evidence as unauthentic or insufficiently probative.
The Board issued its own opinion (did not adopt the IJ’s) and reviewed the record de novo under the substantial-evidence standard.
The Board concluded Adamu failed to meet his burden to establish past persecution or a well‑founded fear of future persecution, and thus denied asylum, withholding, and CAT relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of corroboration for asylum eligibility	Adamu argued his credible testimony plus submitted documents proved persecution or a well‑founded fear.	Government argued key corroborating documents lacked authenticity or probative value so record was insufficient.	Court upheld Board: documentary evidence properly discounted; substantial evidence supports denial.
Effect of IJ silence on credibility	Adamu relied on IJ’s silence to invoke presumption of credibility on appeal.	Government contended corroboration still required where reasonable to expect it.	Court: presumption applied but corroboration may be required; absence justified denial here.
Withholding of removal (higher standard)	Adamu contended he met the clear‑probability standard given his testimony and evidence.	Government argued inability to meet heightened burden given lack of reliable corroboration.	Court: denial affirmed because asylum failure foreclosed withholding and record did not show clear probability.
CAT protection (torture standard)	Adamu argued removal would more likely than not result in torture.	Government argued record did not establish likelihood of torture upon return.	Court: affirmed denial—applicant failed to meet CAT’s "more likely than not" standard.

Djadjou v. Holder, 662 F.3d 265 (4th Cir. 2011) (definitions and burdens for asylum and withholding)
Marynenka v. Holder, 592 F.3d 594 (4th Cir. 2010) (corroboration required where reasonable to expect it; credibility presumption)
Mulyani v. Holder, 771 F.3d 190 (4th Cir. 2014) (substantial‑evidence review and reversal standard)
Lin‑Jian v. Gonzales, 489 F.3d 182 (4th Cir. 2007) (presuming credibility when IJ silent)
Dankam v. Gonzales, 495 F.3d 113 (4th Cir. 2007) (CAT need not be tied to a protected ground)
Martinez v. Holder, 740 F.3d 902 (4th Cir. 2014) (review the Board’s opinion when it issues its own)
Eta‑Ndu v. Gonzales, 411 F.3d 977 (8th Cir. 2005) (upholding denial where corroborating evidence lacked authenticity)