Meihua Piao v. Sessions, 697 F. App'x 73

Petitioner Meihua Piao, a Chinese national, sought asylum, withholding of removal, and CAT protection; IJ denied relief and BIA affirmed. Petition for review to 2d Cir. followed.
Central factual claims: Piao alleged pregnancy and abortion in China (critical to her claim) and later fled to the U.S. claiming fear of persecution.
Documentary evidence: hospital records showing treatment at a different hospital than Piao initially testified to; passport/entry information and interview statements with inconsistent descriptions of how/when she entered the U.S.
At hearing, Piao gave varying testimony about (a) which hospital confirmed her pregnancy and performed the abortion, (b) the date she left China and arrived in the U.S., and (c) which passport she used to enter the U.S.
IJ found Piao not credible based on these inconsistencies; BIA affirmed (except it did not rely on one IJ finding about an IUD inconsistency). Court reviewed under substantial-evidence and REAL ID Act credibility standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the agency reasonably found Piao not credible	Piao argued her explanations (grief, memory problems) and corroborating documents justify crediting her testimony	Government argued multiple, material inconsistencies in testimony vs. records undermined credibility	Court held substantial evidence supports adverse credibility finding; not compelled to credit Piao
Whether inconsistencies about hospital location were material	Piao said memory problems after brother’s death explain discrepancy	Government pointed to hospital records showing a different hospital 40 minutes away and application saying she had no siblings	Court held discrepancy was significant because abortion is core to claim and explanation was not compelling
Whether inconsistent dates of departure/arrival fatally undermine claim	Piao argued date variations were minor and passport stamp supports her timeline	Government emphasized repeated contradictory testimony on basic chronology	Court held date inconsistencies further undermined credibility; unexhausted arguments not considered
Whether IJ ignored corroborating evidence	Piao argued IJ failed to consider supporting documents	Government noted IJ listed and considered evidence and discussed hospital records specifically	Court held IJ sufficiently considered corroboration; no requirement to parse every item on record

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir. 2005) (standard for reviewing BIA modifications to IJ decision)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (REAL ID Act credibility standard and deference to credibility findings)
Tu Lin v. Gonzales, 446 F.3d 395 (2d Cir. 2006) (cumulative effect of collateral inconsistencies may be consequential)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (petitioner must show a reasonable factfinder would be compelled to credit testimony)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (same factual predicate defeats multiple forms of relief when credibility is dispositive)
Wei Guang Wang v. Bd. of Immigration Appeals, 437 F.3d 270 (2d Cir. 2006) (IJ need not parse or refute every piece of evidence on record)
Xiao Ji Chen v. U.S. Dep’t of Justice, 471 F.3d 315 (2d Cir. 2006) (presumption that IJ considered all evidence unless record suggests otherwise)
Lin Zhong v. U.S. Dep’t of Justice, 480 F.3d 104 (2d Cir. 2007) (issue-exhaustion requirement for claims on appeal)
Diallo v. INS, 232 F.3d 279 (2d Cir. 2000) (minor date inconsistencies may be harmless)
Poradisova v. Gonzales, 420 F.3d 70 (2d Cir. 2005) (some indication required that IJ considered material corroborating evidence)