Svetlana Grigore Sumschi v. U.S. Attorney General, 677 F. App'x 579

Petitioner Svetlana Grigore Sumschi, a Moldovan citizen, appealed the BIA’s affirmance of an IJ’s denial of asylum, withholding of removal, and CAT relief after she alleged political persecution for opposing the Communist Party.
Alleged incidents: trampling during an anti-Communist demonstration (chaotic police dispersal), a subsequent elevator confrontation where a woman held a knife to her throat and threatened her and her family, and threatening phone calls thereafter; no further direct confrontations after November 2010 and she remained in Moldova nearly a year after the elevator incident.
Sumschi argued she faces future political persecution due to Communist activity, government corruption, and human rights abuses in Moldova.
The BIA and IJ found her past mistreatment did not rise to persecution and that she failed to show an objectively reasonable fear of future persecution; they also denied withholding of removal and CAT relief.
The Eleventh Circuit reviewed factual findings under the substantial-evidence standard and reached the merits for the well-founded fear claim, concluding exhaustion was adequate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sumschi suffered past persecution	Her assaults, death threats, and harassment for opposing Communists amounted to persecution	Incidents were isolated/harassment, not severe or targeted enough to constitute persecution	Denied — cumulative incidents did not compel finding of persecution
Whether Sumschi has a well‑founded fear of future persecution	Continued Communist targeting, government corruption, and human-rights abuses mean a reasonable objective fear exists	Political power shifted away from Communists; no evidence of ongoing targeting; government protections and reforms exist	Denied — record supports conclusion fear is not objectively reasonable
Whether withholding of removal is warranted	Higher standard than asylum but met because of risk from political actors	Failure to meet asylum standard means withholding standard not met	Denied — did not meet the more likely‑than‑not standard
Whether CAT relief is warranted	Likely tortured if returned given police abuse and corruption	Record does not show it is more likely than not she would be tortured	Denied — substantial evidence supports denial of CAT relief

Gonzalez v. U.S. Att’y Gen., 820 F.3d 399 (11th Cir. 2016) (review of BIA as final judgment)
Adefemi v. Ashcroft, 386 F.3d 1022 (11th Cir. 2004) (substantial‑evidence standard for factual findings)
Diallo v. U.S. Att’y Gen., 596 F.3d 1329 (11th Cir. 2010) (need specific, credible evidence to establish persecution)
De Santamaria v. U.S. Att’y Gen., 525 F.3d 999 (11th Cir. 2008) (repeated threats and severe mistreatment can constitute persecution)
Rodriguez v. U.S. Att’y Gen., 735 F.3d 1302 (11th Cir. 2013) (persecution is an extreme concept; mere harassment insufficient)
Djonda v. U.S. Att’y Gen., 514 F.3d 1168 (11th Cir. 2008) (examples where detention/beatings did not compel persecution finding)
Sanchez Jimenez v. U.S. Att’y Gen., 492 F.3d 1223 (11th Cir. 2007) (attempted murder constitutes persecution)
Indrawati v. U.S. Att’y Gen., 779 F.3d 1284 (11th Cir. 2015) (exhaustion of administrative remedies standard)