Singh v. Garland, 20-1191

Petitioner Gurjaspreet Singh, an Indian national, sought asylum, withholding of removal, and CAT relief based on two politically-motivated attacks tied to his support for the Shiromani Akali Dal Amritsar Party.
Singh filed a detailed written application and testified before an Immigration Judge (IJ) that he received medical treatment after both attacks and that his father accompanied him to the clinic and (on one occasion) to the police station.
The IJ found Singh not credible, relying on omissions in his written statement (medical treatment and his father’s presence) and inconsistent testimony about the severity of his injuries and how he obtained supporting letters.
The IJ gave minimal weight to corroborating letters because they contained errors/omissions and Singh’s explanations for how he obtained them were inconsistent.
The Board of Immigration Appeals (BIA) affirmed the IJ’s adverse credibility finding; the Second Circuit reviewed the decision under the deferential substantial-evidence standard and denied the petition for review.

Issue	Singh's Argument	Garland's Argument	Held
Whether the IJ permissibly found Singh not credible based on omissions and inconsistent testimony	Omissions were inadvertent or minor; testimony supports his account	Omissions (medical treatment, father at clinic/police) and inconsistent descriptions of injuries justify adverse credibility	Court upheld adverse credibility finding as supported by substantial evidence
Whether omission of medical treatment required corroboration or was too minor to affect credibility	Medical details were not central and omission was harmless	Medical treatment was substantial and Singh volunteered it at hearing, so omission undermined credibility	Court found the omission material given the testimony and nature of treatment
Whether supporting letters were reliable corroboration	Letters corroborate his political support and attacks	Letters had errors/omissions and Singh gave inconsistent accounts of obtaining them, so they merit little weight	Court agreed agency reasonably afforded the letters minimal weight
Whether adverse credibility forecloses asylum, withholding, and CAT relief	Even if credibility adverse, other evidence could sustain relief	All relief depends on the same factual predicate; credibility dispositive	Court held the adverse credibility finding dispositive and denied all relief

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir. 2005) (standard: review BIA decision as modified by IJ)
Hong Fei Gao v. Sessions, 891 F.3d 67 (2d Cir. 2018) (review of adverse credibility under substantial-evidence standard)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (deference to IJ credibility findings unless no reasonable fact-finder could make them)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (applicant must do more than offer a plausible explanation for inconsistencies)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (failure to corroborate can bear on credibility)
Y.C. v. Holder, 741 F.3d 324 (2d Cir. 2013) (deference to agency’s evaluation of documentary evidence weight)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (adverse credibility as dispositive across asylum, withholding, and CAT when based on same facts)