Shi Bo Wang v. Sessions, 697 F. App'x 28

Petitioner Shi Bo Wang, a Chinese national, sought asylum, withholding of removal, and CAT protection based on mistreatment by Chinese authorities.
An Immigration Judge (IJ) denied relief in September 2013, finding Wang not credible; the Board of Immigration Appeals (BIA) affirmed on May 4, 2015.
The IJ’s adverse credibility finding rested on demeanour (hesitation, seeming memorization), multiple inconsistencies in Wang’s testimony, and insufficient corroboration.
Disputed factual inconsistencies included: how often police searched his mother’s house, whether his mother treated his post-detention injuries, how he learned about U.S. asylum, and his relation to a cousin.
Corroborating evidence (a letter from Wang’s mother) was given limited weight as outdated and from an interested witness; Wang failed to provide statements from siblings.
The Second Circuit reviewed both IJ and BIA opinions and denied the petition for review, holding the adverse credibility determination supported by substantial evidence and dispositive of all claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the agency’s adverse credibility finding was supported by substantial evidence	Wang argued his testimony was credible and corroborated; inconsistencies were not definitive	Government argued demeanor, inconsistencies, and lack of corroboration justified disbelief	Court held the adverse credibility determination was supported by substantial evidence
Whether Wang sufficiently corroborated his claim to rehabilitate testimony	Wang relied on his mother’s letter and offered limited documentary proof	Government argued the mother’s letter was stale, from an interested witness, and did not resolve key inconsistencies; siblings’ statements absent	Court found corroboration inadequate and properly discounted the mother’s letter
Whether credibility ruling foreclosed asylum and withholding claims	Wang argued credibility problems were not dispositive of all relief	Government maintained all claims relied on same factual predicate and thus failed with credibility loss	Court held the credibility finding was dispositive and denied asylum and withholding
Whether CAT relief required separate consideration despite credibility issues	Wang contended CAT claim might succeed independently	Government argued CAT claim rested on same factual predicate and was defeated by adverse credibility	Court held CAT relief failed because it was based on the same unsupported facts

Wangchuck v. Dep’t of Homeland Sec., 448 F.3d 524 (2d Cir. 2006) (review of IJ and BIA opinions for completeness)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (standards for credibility and review)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (deference to IJ credibility findings and requirement for compelling explanations)
Li Hua Lin v. U.S. Dep’t of Justice, 453 F.3d 99 (2d Cir. 2006) (use of inconsistencies to support adverse credibility)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (failure to corroborate may bear on credibility)
Y.C. v. Holder, 741 F.3d 324 (2d Cir. 2013) (weight of corroboration from interested witnesses)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (common factual predicate doctrine for asylum, withholding, and CAT)
Zhou Yun Zhang v. U.S. INS, 386 F.3d 66 (2d Cir. 2004) (requirement that petitioner do more than offer plausible explanations for inconsistencies)