Lin v. Holder, 656 F.3d 605

Yan Lin, a Chinese national from Fujian, seeks asylum based on alleged forced abortion by family-planning authorities.
An IJ denied asylum, finding Lin credible about the abortion but not involuntary, citing hospital certificates suggesting voluntariness.
The hospital documents stated Lin had an abortion and recommended bed rest but did not specify voluntariness; Lin says they were provided automatically upon discharge.
The State Department’s 2007 country profile suggested abortion certificates exist only for voluntary abortions and not for forced ones.
The Board of Immigration Appeals affirmed, adopting the IJ’s reasoning that Huang v. Gonzales supported the adverse credibility finding.
The Seventh Circuit vacates and remands, holding Huang was misapplied and the credibility assessment requires corroboration beyond generalized country reports.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Huang require an adverse credibility finding here?	Lin argues Huang overstated its holding and allowed corroboration to rebut it.	Respondent contends Huang supports relying on the abortion certificate and country profile to deny credibility.	No; Huang does not mandate a per se adverse finding.
Was the IJ's reliance on abortion certificates proper?	Lin provided corroboration and the certificate should not alone destroy credibility.	Certificate, with country profile, undermines credibility absent corroboration.	Incorrectly relied on; requires additional corroboration.
Did the Board properly require corroboration under the REAL ID Act?	Lin offered a family letter; corroboration was reasonable and available.	Board allowed lack of corroboration to justify denial based on country report.	Board failed to justify requiring corroboration; remand necessary.
May country reports alone support an adverse credibility finding?	Country reports are evidence but not controlling; need specific testimony.	Country report can inform credibility analysis.	Over-reliance on country reports is improper; not dispositive.

Huang v. Gonzales, 453 F.3d 942 (7th Cir. 2006) (abortion certificate evidence may affect credibility but not mandatorily)
Krishnapillai v. Holder, 563 F.3d 606 (7th Cir. 2009) (REAL ID Act corroboration may be required when reasonably obtainable)
Tandia v. Gonzales, 487 F.3d 1048 (7th Cir. 2007) (need to explain why corroboration is reasonably expected)
Torres v. Mukasey, 551 F.3d 616 (7th Cir. 2008) (limits on use of generalized country conditions in credibility)
Bace v. Ashcroft, 352 F.3d 1133 (7th Cir. 2003) (caution against relying on generalized country reports for credibility)
Galina v. INS, 213 F.3d 955 (7th Cir. 2000) (warns against overvaluing generalized country conditions)