Mariya Georgieva v. Eric Holder, Jr., 751 F.3d 514

Georgieva and Dimitrov, Bulgarian Roma, entered the U.S. in 2002 and applied for asylum in 2003; Georgieva was the principal applicant and Dimitrov a derivative.
Georgieva alleged past abuses: childhood school assault, attempted sale into sex trafficking around 2000 in Macedonia, and a 2002 beating outside a Roma advocacy office; documentary support was limited (passport page, Euroroma card, dental records, husband’s testimony).
Significant inconsistencies existed between Georgieva’s written asylum statement and her hearing testimony about the Macedonia trafficking episode (whether she had sex, how and when she escaped, and travel time), and about post-beating medical treatment.
The immigration judge found Georgieva not credible, concluding the discrepancies went to the heart of her asylum claim and that she failed to adequately explain or corroborate them; the IJ denied asylum, withholding, and CAT relief.
The Board of Immigration Appeals affirmed the IJ, denied a remand for ineffective-assistance-of-counsel, and found counsel competent; the Seventh Circuit denied the petition for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility of Georgieva’s testimony	Discrepancies caused by clerical/translation errors and counsel misunderstandings; hearing testimony is accurate	Discrepancies are material, unexplained, and undermine credibility	Court affirmed adverse credibility finding — inconsistencies “go to the heart” and were not plausibly explained
Burden to corroborate where testimony is disbelieved	Documentary gaps excused by translation/preparation problems and past counsel errors	Applicant must explain lack of corroboration or produce credible extrinsic evidence	Court held applicant failed to provide adequate corroboration or to justify its absence
Past persecution based on Roma status	Alleged sexual exploitation, beatings, childhood abuse show targeted persecution	Evidence insufficient to link harms to Roma membership or to meet severity for persecution	Court held petitioner failed to prove past persecution; corroboration did not show race-based motive
Well-founded fear / pattern-or-practice of persecution for Roma in Bulgaria	Roma face pervasive discrimination and violence; fear of future harm is reasonable	Evidence shows discrimination but not systematic, state-tolerated persecution warranting asylum	Court held no established pattern-or-practice of extreme persecution; objective risk not met; asylum/withholding/CAT denied

Capric v. Ashcroft, 355 F.3d 1075 (7th Cir.) (credibility standards and need for corroboration pre-Real ID)
Ahmad v. INS, 163 F.3d 457 (7th Cir.) (upholding adverse credibility where applicant downgraded allegations)
Mitreva v. Gonzales, 417 F.3d 761 (7th Cir.) (Roma discrimination in Bulgaria insufficient to show pattern-or-practice persecution)
Xiao v. Mukasey, 547 F.3d 712 (7th Cir.) (single discrepancy can justify rejecting entire testimony)
Toure v. Holder, 624 F.3d 422 (7th Cir.) (standard for withholding and CAT relief)