Zhi Liu v. Sessions, 697 F. App'x 714

Zhi Liu, a Chinese national, sought asylum, withholding of removal, and CAT relief based on: (1) pro-democracy political activities in the U.S. and (2) a 2007 beating by local Chinese officials.
Immigration Judge denied relief; BIA affirmed on April 29, 2016. Liu petitioned this Court for review.
Key evidentiary weaknesses: inconsistent testimony about reporting subsequent police encounters, conflicting statements about informing CFDP leadership, and differing explanations for his first U.S. trip.
Liu did not submit corroborating statements from his cousin or ex-wife; he asserted they feared retaliation or were estranged.
Liu pointed to online articles/photos and CFDP involvement as showing Chinese authorities’ likely awareness of his U.S. activism.
The agency found the extortion-related 2007 beating was not on account of a protected ground and that Liu failed to show likelihood of future torture.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Liu has an objectively reasonable fear of persecution based on U.S. political activities	Liu: Chinese authorities know or are likely to learn of his activism (online posts, CFDP membership); past harassment of family supports risk	Govt: Liu failed to corroborate key facts; inconsistencies undermined credibility; online material and general harassment insufficient to show official awareness or pattern	Denied — substantial evidence supports agency that Liu failed to show government awareness or pattern/practice; corroboration required and lacking
Whether 2007 beating by local officials was on account of a protected ground or supports CAT relief	Liu: beating and extortion by officials demonstrates persecution and risk of future harm; asserted familial or imputed political motive	Govt: Beating resulted from general extortion of vendors, not on protected ground; no evidence of motive or likelihood of future torture	Denied — agency reasonably found beating was criminal/extortionate conduct not motivated by protected ground and Liu failed to show future likelihood of torture

Y.C. v. Holder, 741 F.3d 325 (2d Cir. 2013) (standard for reviewing asylum claims and need to show authorities’ awareness or pattern/practice)
Ramsameachire v. Ashcroft, 357 F.3d 169 (2d Cir. 2004) (objective well-founded fear and CAT standards)
Hongsheng Leng v. Mukasey, 528 F.3d 135 (2d Cir. 2008) (official awareness requirement for political-activity–based claims)
Paul v. Gonzales, 444 F.3d 148 (2d Cir. 2006) (relationship between asylum and withholding findings)