CA7 on 'Reasoned Explanation' - Ni v. Holder

"The courts of appeals have received scores of strikingly similar petitions for review involving Fujian Province in recent years, and we have regularly upheld the BIA’s refusal to grant relief in such proceedings. Routine can be numbing, however, and it can lead to errors. Here, in evaluating...

CA7 (Posner) on Asylum, China, Changed Conditions, Chenery: Liu v. Holder

"The Justice Department insists that the only change was in the petitioner’s personal conditions. That is wrong. It ignores the change in country conditions. In arguing that reopening was barred because the only change was in personal conditions, the Department was once again violating the...

BIA on Reopening: Matter of J-G-, Int. Dec. No. 3788

(1) An alien who is subject to an in absentia removal order need not first rescind the order before seeking reopening of the proceedings to apply for asylum and withholding of removal based on changed country conditions arising in the country of the alien’s nationality or the country to which removal...