Zhongfeng Guo v. Sessions, 696 F. App'x 548

Guo, a PRC citizen, seeks asylum, withholding of removal, and CAT relief from removal in the United States.
IJ denied Guo’s applications on March 10, 2014; BIA affirmed the denial on December 2, 2015.
Guo alleged involvement with the China Democracy Party and pro-democracy activities in the United States.
The agency declined to credit an unsworn letter from Guo’s father about Chinese officials’ knowledge of Guo’s activities.
Guo contends that his online articles and demonstrations abroad would alert Chinese authorities to his activities.
This Court reviews for substantial evidence and whether Guo has a well-founded fear of persecution under applicable standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Well-founded fear standard applied?	Guo contends fear is objectively reasonable.	Agency reasonably found no objective risk.	Denied; no objective well-founded fear shown.
Credibility of Guo's evidence (unsworn letter, online activity)?	Evidence shows awareness by authorities.	Letter is unsworn and unpersuasive; activities speculative.	Denied; credibility and evidentiary weight lacking.
Whether Guo is similarly situated to dissidents persecuted abroad?	Dissidents abroad evidence parallels Guo’s case.	No showing that Guo’s case mirrors persecuted dissidents in China.	Denied; not sufficiently analogous.

Y.C. v. Holder, 741 F.3d 325 (2d Cir. 2013) (well-founded fear requires some likelihood authorities will become aware)
Hongsheng Leng v. Mukasey, 528 F.3d 135 (2d Cir. 2008) (need for objective reasonable fear with support in record)
Jian Xing Huang v. INS, 421 F.3d 125 (2d Cir. 2005) (burden of proof for asylum and related relief)
Ramsameachire v. Ashcroft, 357 F.3d 169 (2d Cir. 2004) (requirement that fear be supported by reliable evidence)
Wangchuck v. Dep’t of Homeland Sec., 448 F.3d 114 (2d Cir. 2006) (complete record review for asylum determinations)