Song Ye v. Lynch, 669 F. App'x 600

Petitioner Song Ye, a Chinese national and Christian, sought asylum, withholding of removal, and CAT relief, claiming past persecution and fear of future persecution for his faith.
An Immigration Judge (IJ) denied relief after finding Ye not credible; the Board of Immigration Appeals (BIA) affirmed that decision on February 24, 2015.
Key factual disputes included when Ye was arrested, the severity of injuries suffered in detention, why he did not seek post-release medical care, and his religious practice (including inability to explain the gospels).
Ye submitted inconsistent testimony, unsworn letters from family/friends, and other evidence the agency found either inconsistent or insufficiently corroborative.
The adverse credibility finding was dispositive because all claims (asylum, withholding, CAT) rested on the same factual predicate.

Issue	Ye's Argument	Lynch's Argument	Held
Whether the agency reasonably found Ye not credible	Ye argued his testimony and submitted evidence showed persecution and fear due to Christianity	DHS argued Ye’s testimony was inconsistent, he was evasive in demeanor, and corroboration was inadequate	Court held substantial evidence supports adverse credibility finding
Whether inconsistencies and demeanor may be relied on even if not "to the heart" of the claim	Ye contended minor inconsistencies should not defeat his claim	DHS relied on statute and precedent permitting credibility findings based on demeanor and inconsistencies generally	Held agency may rely on demeanor and any inconsistencies under 8 U.S.C. §1158(b)(1)(B)(iii) and precedent
Whether lack of doctrinal knowledge undermines religious persecution claim	Ye asserted he proselytized and practiced Christianity in China	DHS noted Ye could not explain the gospels despite claiming proselytization	Held agency reasonably found doctrinal gaps probative of disbelief
Whether unsworn letters and other documentary evidence rehabilitated Ye’s testimony	Ye relied on letters from family/friends and other documents to corroborate his account	DHS argued the letters were unsworn and some evidence conflicted with Ye’s testimony	Held agency reasonably declined to credit inconsistent or unsworn corroboration; overall corroboration insufficient

Wangchuck v. Dep’t of Homeland Sec., 448 F.3d 524 (2d Cir. 2006) (reviewing both IJ and BIA opinions for completeness)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (agency may base credibility on demeanor and inconsistencies)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (demeanor findings can support adverse credibility determinations)
Li Hua Lin v. U.S. Dep’t of Justice, 453 F.3d 99 (2d Cir. 2006) (inconsistencies may support credibility findings)
Rizal v. Gonzales, 442 F.3d 84 (2d Cir. 2006) (doctrinal ignorance can be probative against religious persecution claims)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (corroboration requirement and agency’s discretion to weigh corroborating evidence)
Y.C. v. Holder, 741 F.3d 324 (2d Cir. 2013) (unsworn letters may be given little weight)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (an adverse credibility finding can be dispositive for asylum, withholding, and CAT when claims share the same predicate)
INS v. Bagamasbad, 429 U.S. 24 (1976) (courts need not decide issues unnecessary to the outcome)