Zoila Garcia v. William P. Barr, 954 F.3d 1095

Zoila Deras Garcia, an El Salvadoran citizen, entered the U.S. without inspection in April 2016, conceded removability, and applied for asylum, withholding of removal, and CAT relief.
She claimed membership in the particular social group “El Salvadoran women who are unable to leave a domestic relationship,” based on abuse by Carlos Alberto Alvarenga.
Garcia gave numerous inconsistent statements about key facts: when the relationship began (2004 vs. 2013), the date and number of assaults (December 25, 2015 vs. September 7, 2015), her grandmother’s death date, where she stayed after leaving Alvarenga (San Salvador with an uncle vs. Chalatenango hotel), and when Alvarenga last found her.
She provided no corroborating evidence and was the sole witness at the IJ hearing.
The IJ found Garcia not credible based on the inconsistencies, totality of circumstances, and lack of corroboration, and denied asylum, withholding, and CAT relief. The BIA affirmed the IJ’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the agency’s adverse credibility finding was supported by substantial evidence	Garcia argued the agency erred in finding her not credible	IJ/BIA argued multiple inconsistent, contradictory statements and lack of corroboration justified disbelief	Court held the adverse credibility finding is supported by specific, cogent reasons and affirmed denial
Whether the inconsistencies were material to asylum/withholding/CAT claims	Garcia addressed only some timing inconsistencies and did not satisfactorily explain others	Government emphasized inconsistencies about abuse frequency, dates, locations, and ability to leave the relationship were material	Court held the inconsistencies were material and unexplained, so a reasonable adjudicator need not find her credible
Whether lack of corroboration defeats relief when credibility is adverse	Garcia offered no corroboration and argued limited inconsistencies only	IJ/BIA relied on lack of corroboration plus adverse credibility to deny relief	Court held absence of corroboration, combined with adverse credibility, supports denial under the substantial-evidence standard

Singh v. Gonzales, 495 F.3d 553 (8th Cir. 2007) (describes the substantial-evidence standard for reviewing agency factual findings)
R.K.N. v. Holder, 701 F.3d 535 (8th Cir. 2012) (deference to IJ credibility findings when supported by specific, cogent reasons)
Chakhov v. Lynch, 837 F.3d 843 (8th Cir. 2016) (agency may consider internal inconsistencies and lack of corroboration when assessing credibility)