CA7 on Corroboration, Asylum, Zimbabwe: Sibanda v. Holder

"After fleeing from her native Zimbabwe to the United States, Lucy Sibanda applied for asylum and other relief from removal. She fears that if she is repatriated, her brother‐in‐law will exercise his rights under a tribal custom that deems her, his brother’s widow, his property and will attempt to rape her as he has done before. The immigration judge denied Sibanda’s application, in part for lack of corroboration of the alleged custom and the attempted rapes. The Board of Immigration Appeals found her account credible, but it dismissed her appeal because of insufficient corroboration for her story.  The Board did not, however, adequately consider whether more corroborating information was reasonably available to Sibanda, and it appears to us that it was not. We therefore grant the petition for review and remand to the agency for further proceedings. ... 

The Board assumed, and so will we, that Sibanda is credible. We thus turn immediately to the question whether the record compels the conclusion that (more) corroborating evidence was not reasonably available. The answer, we conclude, is yes. Under the circumstances, Sibanda could not be expected to furnish a supporting “letter or affidavit” from her own family or tribe. [Also see pp. 8-9 re IJ reliance on Wikipedia.]" - Sibanda v. Holder, Feb. 13, 2015.