Lin v. Garland, 20-370

Petitioner Bing Qing Lin, a Chinese national, applied for asylum, withholding of removal, and CAT protection claiming detention and physical abuse in China for attending an unauthorized Christian church.
An Immigration Judge (IJ) denied relief in April 2018; the Board of Immigration Appeals (BIA) affirmed in January 2020. Lin petitioned the Second Circuit for review.
The agency found Lin not credible based on inconsistencies about her confinement conditions, alleged mistreatment, reasons for leaving China, and her U.S. residence.
The IJ also made an adverse demeanor finding (which Lin did not challenge) and gave little weight to corroborating documents because of misspellings and authorship by interested witnesses.
The Second Circuit reviewed the credibility determination under the substantial-evidence standard and denied the petition, holding the adverse credibility finding supported the denial of all forms of relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the IJ/BIA’s adverse credibility determination is supported by substantial evidence	Lin argued inconsistencies were explained and not material	Government argued inconsistencies, demeanor, and weak corroboration justified disbelief	Court held substantial evidence supports the adverse credibility finding
Whether plausible explanations required the agency to credit Lin’s testimony	Lin argued her explanations resolved inconsistencies so she should be credited	Government argued explanations did not compel crediting under Majidi standard	Court held petitioner must show a reasonable factfinder would be compelled to credit testimony; she did not
Whether corroborating evidence rehabilitated Lin’s testimony	Lin argued documents and witness statements corroborated her claim	Government argued documentary problems and interested-witness letters had little weight	Court held corroboration was insufficient to rehabilitate testimony
Whether adverse credibility ruling forecloses asylum, withholding, and CAT relief	Lin argued relief still available despite credibility issues	Government argued all claims rested on same factual predicate so credibility defeat ends all relief	Court held adverse credibility dispositive for all three forms of relief

Wangchuck v. Dep’t of Homeland Sec., 448 F.3d 524 (2d Cir. 2006) (court may consider both IJ and BIA opinions)
Hong Fei Gao v. Sessions, 891 F.3d 67 (2d Cir. 2018) (substantial-evidence review; IJs may rely on non-material inconsistencies)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (defer to IJ credibility findings unless no reasonable factfinder could reach them)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (applicant must show a reasonable factfinder would be compelled to credit testimony)
Siewe v. Gonzales, 480 F.3d 160 (2d Cir. 2007) (deference where two permissible views of evidence exist)
Li Hua Lin v. U.S. Dep’t of Justice, 453 F.3d 99 (2d Cir. 2006) (particular deference to IJ demeanor findings)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (lack of corroboration may bear on credibility)
Y.C. v. Holder, 741 F.3d 324 (2d Cir. 2013) (defer to agency’s evaluation of documentary evidence)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (adverse credibility can be dispositive for asylum, withholding, and CAT when claims share the same predicate)
Hui Lin Huang v. Holder, 677 F.3d 130 (2d Cir. 2012) (reversing BIA on other grounds)