CA9 on BIA 'Shell Game' - Zhao v. Holder

CA9 on BIA 'Shell Game' - Zhao v. Holder

"Absent some reasoned explanation appropriate to the particular circumstances, the BIA simply cannot shift its proof requirements. To do so is to subject petitioners to an administrative shell game.  Therefore, under the circumstances presented by this case, it was contrary to law and an abuse of discretion for the BIA to require Zhao to provide Duhu Town-specific evidence of local policy and enforcement." - Zhao v. Holder, Sept. 6, 2013.  [Hats off to Ted Cox and team!]