Yongcai Lin v. Sessions, 685 F. App'x 57

Petitioner Yongcai Lin, a Chinese national, appealed the BIA’s October 19, 2015 decision affirming an IJ’s denial of asylum, withholding of removal, and CAT relief.
Lin waived any challenge to denial of asylum as time-barred; the only issue on review was the agency’s adverse credibility determination.
Discrepancies identified by the agency included: whether Lin ever attended a government-sponsored church (asylum interview: yes; hearing: no) and when he began attending an underground family church (asylum interview: 2007; hearing: ~2003).
Lin gave inconsistent descriptions of a beating in detention between his asylum application and his hearing testimony.
Corroborating evidence was limited and did not explain the absence of a letter from Lin’s parents regarding his detention/release; the agency found the corroboration insufficient to rehabilitate credibility.
Because all claims relied on the same factual predicate, the adverse credibility finding was dispositive of all requested relief; the petition for review was denied.

Issue	Lin's Argument	Sessions' Argument	Held
Whether the agency reasonably made an adverse credibility determination	Lin argued his explanations (e.g., parents "took a look" at government church; attended family church earlier) were plausible	Agency argued multiple material inconsistencies and insufficient corroboration justified disbelief	Court held substantial evidence supports the adverse credibility ruling
Whether minor inconsistencies about church attendance compelled crediting testimony	Lin contended inconsistencies were explainable and not dispositive	Agency treated the timing and attendance contradictions as material to credibility	Court deferred to agency; explanation not compelling under Majidi standard
Whether differences in descriptions of physical abuse undermined credibility	Lin maintained his account of beating was consistent in substance	Agency relied on differing descriptions between application and hearing responses	Court sustained adverse credibility due to inconsistent descriptions and lack of responsiveness
Whether corroboration could rehabilitate Lin’s testimony	Lin offered some documents from father but lacked a parents’ letter about detention/release	Agency argued reasonably available corroboration was missing and thus insufficient	Court agreed corroboration was inadequate to overcome credibility defects

Xue Hong Yang v. U.S. Dep’t of Justice, 426 F.3d 520 (2d Cir.) (standard for reviewing IJ decision as modified by BIA)
Yueqing Zhang v. Gonzales, 426 F.3d 540 (2d Cir. 2005) (asylum-time-bar waiver principles)
Xiu Xia Lin v. Mukasey, 534 F.3d 162 (2d Cir. 2008) (substantial-evidence review of credibility determinations)
Majidi v. Gonzales, 430 F.3d 77 (2d Cir. 2005) (applicant must compel reasonable fact-finder to credit explanations for inconsistencies)
Lianping Li v. Lynch, 839 F.3d 144 (2d Cir. 2016) (inconsistencies in descriptions of persecution support adverse credibility)
Biao Yang v. Gonzales, 496 F.3d 268 (2d Cir. 2007) (failure to corroborate may bear on credibility)
Chuilu Liu v. Holder, 575 F.3d 193 (2d Cir. 2009) (absence of available corroboration can suffice to deny relief)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (adverse credibility finding dispositive when claims share same factual predicate)