Jauri Hamzah v. Eric Holder, Jr., 428 F. App'x 551

Hamzah is an Indonesia-born convert from Islam to Christianity who seeks withholding of removal based on past persecution and fear of future persecution.
He was born in Makassar and belongs to the Watamvone indigenous tribe; his father was Muslim, his mother Christian.
Hamzah converted to Christianity in 1985, baptized, and married a Christian woman in 1993; he faced threats from family and extremist Muslims after conversion.
He lived in Indonesia for about 12 years post-conversion, including time in Jakarta, where he alleges threats and public hostility toward Christians.
Hamzah moved to the United States in 1997; DHS initiated removal proceedings in 2003; he was designated to Indonesia as the country of removal.
The IJ denied asylum, withholding of removal, and CAT, based on timeliness, lack of credibility, and absence of past persecution or well-founded fear; the BIA affirmed in 2009.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hamzah proved past persecution based on religion	Hamzah contends threats and hostility after conversion show past persecution	BIA/IJ found no substantiated harm or credible threats; not past persecution	Denial affirmed; no past persecution established
Whether Hamzah proved a well-founded fear of future persecution if returned	Hamzah argues ongoing threats and government inability to protect him due to conversion	Country reports show religious freedom and no evidence of systemic risk to converts	Denial affirmed; no well-founded fear established

Haider v. Holder, 595 F.3d 276 (6th Cir. 2010) (assess credibility when BIA adopts IJ grounds for denial)
Acquaah v. Holder, 589 F.3d 332 (6th Cir. 2009) (review IJ/BIA order as final administrative order)
Pablo-Sanchez v. Holder, 600 F.3d 592 (6th Cir. 2010) (clear probability standard for withholding; past persecution creates presumption of future fear)
Mullai v. Ashcroft, 385 F.3d 635 (6th Cir. 2004) (country reports as best sources on conditions; generally reliable)