Yuehua Liu v. U.S. Attorney General, 665 F. App'x 829

Yuehua Liu, a Chinese national, sought asylum, withholding of removal, and CAT relief based on persecution for participating in an underground Christian church.
Liu testified she was arrested in October 2006, detained seven days, interrogated twice, and during the second interrogation was slapped, kicked, and had her hair pulled; she did not seek medical treatment or report injuries.
Liu lost her job after the arrest and claimed economic hardship but offered no corroborating evidence of being unable to earn a living or of job-search efforts.
Other members of Liu’s home church who were arrested continued to live and work in China without reported harm for years after her arrest.
She submitted a 2014 letter reporting another raid on a house church, but the letter lacked details about detentions or mistreatment; there was no record of persecution of her church members between 2006 and 2014.
The IJ denied relief; the BIA affirmed. Liu petitioned for review in the Eleventh Circuit, which applied substantial-evidence review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Liu suffered past persecution on account of religion	Liu argued week-long detention with physical abuse and job loss constituted persecution	Government argued abuse was limited, produced no medical need, and similar or lesser harms were held non-persecutory	Held: Substantial evidence supports denial — harm did not rise to persecution
Whether Liu has a well-founded fear of future persecution	Liu argued police interest, continued questioning, and later raids show reasonable possibility of future harm	Government argued lack of pattern or practice of persecuting Christians and that church members remained safe in China	Held: Substantial evidence supports denial — no reasonable possibility of future persecution
Whether Liu is entitled to withholding of removal and CAT relief	Liu contended her facts supported the higher standard for withholding and CAT protection	Government contended Liu failed to meet asylum standard and thus cannot meet higher withholding or CAT standards	Held: Denied — failure to meet asylum standard precludes withholding and CAT relief
Jurisdictional/alternative claims (imputed political opinion, nexus)	Liu raised imputed political opinion and nexus arguments on appeal	Government noted failure to exhaust before BIA; BIA decision did not rest on nexus	Held: Court lacks jurisdiction to review imputed political opinion; nexus not properly before the court

Ruiz v. U.S. Att’y Gen., 440 F.3d 1247 (11th Cir. 2006) (asylum eligibility requires past persecution or well-founded fear)
Sepulveda v. U.S. Att’y Gen., 401 F.3d 1126 (11th Cir. 2005) (withholding of removal standard is more stringent than asylum)
Shi v. U.S. Att’y Gen., 707 F.3d 1231 (11th Cir. 2013) (longer detentions and singularly cruel tactics can constitute persecution)
Kazemzadeh v. U.S. Att’y Gen., 577 F.3d 1341 (11th Cir. 2009) (isolated incidents and brief detentions may not constitute persecution)
Djonda v. U.S. Att’y Gen., 514 F.3d 1168 (11th Cir. 2008) (short detentions and non-serious physical abuse may fall short of persecution)
Zheng v. U.S. Att’y Gen., 451 F.3d 1287 (11th Cir. 2006) (five-day detention, mistreatment, and job loss did not compel finding of persecution)
Niftaliev v. U.S. Att’y Gen., 504 F.3d 1211 (11th Cir. 2007) (long detentions with multiple beatings and hospitalization can constitute persecution)
Ruiz v. Gonzalez, 479 F.3d 762 (11th Cir. 2007) (extended detention with threats and multiple beatings may be persecution)
Al Najjar v. Ashcroft, 257 F.3d 1262 (11th Cir. 2001) (standard for well-founded fear and requirement for specific, detailed facts)