Rajwinder Singh v. Merrick Garland, 20-4173

Rajwinder Singh, a Sikh from Punjab, India, entered the U.S. without inspection in 2003 and applied for asylum, claiming police arrests, beatings, and harassment tied to his Sikh political-party membership and religion.
Singh submitted corroboration: a 2010 letter from a Punjabi attorney attaching an English-language arrest warrant, a 2003 affidavit from his father, and a 2011 letter from his wife describing ongoing police harassment.
The IJ in 2011 found Singh’s evidence and testimony questionable, concluded the arrest warrant appeared fraudulent, and denied asylum and CAT relief; BIA remanded for an express credibility finding.
On remand Singh submitted updated letters but no new testimony; the IJ in 2018 expressly found him not credible and again denied relief; the BIA affirmed and held Singh waived his CAT claim by not arguing it on appeal.
Singh petitioned the Sixth Circuit, arguing the adverse credibility finding was unsupported and that a single fraudulent document should not be dispositive given his other corroboration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adverse credibility	Singh: inconsistencies minor; testimony otherwise credible	Gov: key inconsistency (fraudulent warrant) and vague testimony justify adverse finding	Court: Upheld adverse credibility; fraudulent warrant dispositive under precedent
Weight of one fraudulent document	Singh: court should weigh fraud against other credible evidence, not treat it as conclusive	Gov: Selami controls; a single fraudulent key document can support adverse credibility	Court: Followed Selami; a fraudulent submission going to the heart of the claim supports adverse credibility
Sufficiency of corroboration for asylum/withholding	Singh: attorney letter, father’s affidavit, wife’s letter corroborate fear and past abuse	Gov: those documents are unreliable and do not cure credibility defects	Court: Because testimony rejected, corroboration inadequate; asylum and withholding denied
CAT claim	Singh: argued relief overall (but did not press CAT on appeal)	Gov: CAT claim waived for failure to brief it before BIA	Court: Agreed CAT claim waived by Singh’s failure to raise it on appeal

Khalili v. Holder, 557 F.3d 429 (6th Cir. 2009) (scope of review; review of BIA decisions and adopted IJ reasoning).
Marikasi v. Lynch, 840 F.3d 281 (6th Cir. 2016) (credibility and withholding-of-removal standards; assessing testimony predating REAL ID Act).
Selami v. Gonzales, 423 F.3d 621 (6th Cir. 2005) (a single fraudulent submission that goes to a key claim can support an adverse credibility finding).
Abdurakhmanov v. Holder, 735 F.3d 341 (6th Cir. 2012) (testimony found not credible when inconsistencies go to the heart of the claim).
Cruz-Samayoa v. Holder, 607 F.3d 1145 (6th Cir. 2010) (asylum statutory standard for past persecution or well-founded fear).
Dorosh v. Ashcroft, 398 F.3d 379 (6th Cir. 2004) (standards on adequacy and availability of corroboration).
Wright v. Spaulding, 939 F.3d 695 (6th Cir. 2019) (court bound by existing circuit precedent; cannot disregard controlling authority).
Kouljinski v. Keisler, 505 F.3d 534 (6th Cir. 2007) (discussing asylum burden and protected grounds).