Jie Liu v. Jefferson Sessions, 891 F.3d 834

Liu, a Chinese national, claims persecution for resisting China’s family planning policies: his wife allegedly was forcibly aborted and sterilized, and Liu was detained after confronting officials.
He entered the U.S. on a B-1 visa, overstayed, and was placed in removal proceedings in 2009.
Liu applied for asylum and withholding of removal, conceding removability.
The IJ warned before the merits hearing that corroborating evidence would be required; nearly a year later Liu produced only a marriage certificate, residency card, and household registry.
The IJ found inconsistencies in Liu’s testimony and that, even if credible, his testimony lacked persuasive, specific corroboration of the abortion/sterilization and his detention; the IJ denied relief.
The BIA affirmed based on failure to provide reasonably attainable corroboration and lack of past or well-founded fear of future persecution; Liu petitioned for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the IJ gave proper notice that corroboration was required	Liu: IJ failed to give adequate notice or time to obtain corroboration	Gov: IJ gave explicit notice and counsel acknowledged need for more evidence; petitioner had time	Held: Notice was sufficient; Liu had time to produce corroboration and did not do so
Whether Liu’s testimony alone could support asylum (REAL ID Act corroboration standard)	Liu: His credible testimony should suffice without corroboration	Gov: Even if credible, testimony was not sufficiently persuasive or specific; corroboration required	Held: Even assuming credibility, testimony lacked persuasive specificity; corroboration reasonably required
Whether Liu established past persecution based on forced abortion/sterilization and his detention	Liu: Past persecution due to political opinion (resistance to population control)	Gov: Insufficient corroboration and gaps in factual detail undermine claim	Held: Court did not reach merits because failure to corroborate justified denial; BIA/IJ determinations supported by record
Whether Liu is entitled to withholding of removal	Liu: Withholding follows if persecution established	Gov: Withholding standard more stringent and unavailable absent asylum eligibility	Held: Because Liu is ineligible for asylum, he is also ineligible for withholding of removal

Song v. Sessions, 882 F.3d 837 (9th Cir. 2017) (standard for overturning BIA—only if evidence compels contrary conclusion)
Ren v. Holder, 648 F.3d 1079 (9th Cir. 2011) (IJ must notify applicant what corroboration is required and allow time or explanation for unavailability)
Mansour v. Ashcroft, 390 F.3d 667 (9th Cir. 2004) (withholding of removal standard is more stringent than asylum)