Qiuyun Zheng v. Sessions, 688 F. App'x 51

Petitioner Qiuyun Zheng, a Chinese national, sought asylum, withholding of removal, and CAT protection after claiming he was detained and beaten by family planning officials for posting an anti–family planning sign and later escaped China with a smuggler’s help.
The Immigration Judge denied relief; the Board of Immigration Appeals affirmed in part and modified the IJ’s decision.
The agency found Zheng failed to corroborate key aspects of his account (no statement from the friend who helped make the sign, no certified medical report, no evidence of paying smugglers).
Zheng submitted unsworn letters from relatives and a former fiancée, which the agency gave little weight as they were interested and unsworn.
Because Zheng failed to meet the burden to show past persecution or a well‑founded fear of future persecution on account of opposition to family planning policy, the agency denied asylum, withholding, and CAT relief.

Issue	Zheng's Argument	Sessions' Argument	Held
Whether Zheng proved past persecution / well‑founded fear based on opposition to family planning policy	Zheng asserted he was detained and beaten for posting a sign and later fled with smuggler help	Agency argued Zheng failed to corroborate key facts and testimony lacked detail	Held for Sessions: Zheng failed to provide reasonably available corroboration and persuasive detail; burden not met
Whether unsworn letters from relatives suffice as corroboration	Zheng relied on letters from family and fiancée to corroborate his story	Agency contended letters were interested and unsworn, thus entitled to little weight	Held for Sessions: Letters were properly discounted as unsworn and from interested witnesses
Whether testimony alone could suffice without corroboration	Zheng argued his testimony was credible and sufficient	Agency required corroboration because testimony lacked specific, persuasive detail	Held for Sessions: Agency reasonably required corroboration under 8 U.S.C. §1158(b)(1)(B)(ii) framework
Whether denial of asylum also forecloses withholding and CAT relief	Zheng sought all three forms of protection based on same facts	Respondent argued all relief depends on same factual predicate	Held for Sessions: Denial of asylum dispositive; withholding and CAT denied as based on same failure of proof

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir.) (standard for reviewing agency decision)
Chuilu Liu v. Holder, 575 F.3d 193 (2d Cir.) (corroboration required when testimony not sufficiently detailed)
Shi Liang Lin v. U.S. Dep’t of Justice, 494 F.3d 296 (2d Cir.) (limits on asylum based on spouse/partner’s harm)
Y.C. v. Holder, 741 F.3d 324 (2d Cir.) (letters from interested relatives entitled to little weight when unsworn)
Paul v. Gonzales, 444 F.3d 148 (2d Cir.) (same factual predicate can make asylum denial dispositive for withholding and CAT relief)