Jin Xing Chen v. Sessions, 690 F. App'x 718

Petitioner Jin Xing Chen, a Chinese national, sought asylum, withholding of removal, and CAT protection based on persecution for his Christian faith.
The IJ denied relief after finding Chen not credible; the BIA affirmed.
The agency relied on inconsistencies between Chen’s testimony and documentary evidence (e.g., a letter about a fellow church member’s detention) and Chen’s unfamiliarity with that evidence.
The IJ also found inconsistencies regarding Chen’s U.S. church attendance versus church records and gave diminished weight to a corroborating witness who attended with Chen only once.
The IJ made a demeanor finding (frequent long pauses) suggesting rehearsed testimony; the agency gave reduced weight to interested-party letters and other corroboration.
The Second Circuit reviewed the agency’s adverse credibility determination under the REAL ID Act and denied the petition for review, finding the credibility ruling supported by the totality of the circumstances and dispositive of all claims.

Issue	Chen's Argument	Sessions' Argument	Held
Whether the agency’s adverse credibility finding complied with the REAL ID Act standard	Chen argued inconsistencies were minor/trivial and offered explanations for pauses and discrepancies	Govt. argued inconsistencies, demeanor, and weak corroboration support adverse credibility	Court upheld the adverse credibility finding under the totality of circumstances
Consistency between Chen’s testimony and a letter about Feng Chen’s detention	Chen claimed Feng detained ~40 days and submitted a letter saying 19 days; Chen said he might have forgotten details	Govt. argued Chen’s unfamiliarity with submitted evidence undermined credibility	Court found the inconsistency properly relied upon and damaging to credibility
Church attendance discrepancy (testimony vs. church records)	Chen said he attended weekly/2–3x/month and sometimes forgot to "clock in"	Govt. relied on church log showing 14 visits in ~18 months and lack of corroboration for forgetting to clock in	Court held discrepancy supported adverse credibility; explanation insufficient without corroboration
Weight of corroborating evidence and impact on relief claims	Chen argued letters and a witness supported his claim	Govt. argued letters were from interested parties, witness was limited and inconsistent with Chen’s timeline	Court found corroboration insufficient to rehabilitate testimony; adverse credibility dispositive for asylum, withholding, and CAT

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir.) (reviewing BIA-modified IJ decisions)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir.) (REAL ID Act totality-of-circumstances credibility standard)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir.) (applicant must do more than offer plausible explanation for inconsistencies)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir.) (failure to corroborate can bear on credibility)
Xiao Ji Chen v. U.S. Dep’t of Justice, 471 F.3d 315 (2d Cir.) (weighing documentary evidence lies largely within IJ discretion)
Paul v. Gonzales, 444 F.3d 148 (2d Cir.) (adverse credibility ruling can be dispositive for all relief premised on same facts)