When will adverse credibility findings no longer need to go to the heart of the applicant's claim?

MultiRegion, United States of America

The following excerpt is from Hong Li v. Garland, 18-70943 (9th Cir. 2021):

While we had held prior to the REAL ID Act that inconsistencies forming the basis of an adverse credibility determination should go to the heart of a petitioner's claim, "under the REAL ID Act credibility findings no longer need to go 'to the heart of the applicant's claim.'" Malkandi v. Holder, 576 F.3d 906, 918 (9th Cir. 2009), quoting 8 U.S.C. 1158(b)(1)(B)(iii). "The explicit statutory language and purpose behind the statutory change totally demolish [the] argument that inconsistencies must go to the heart of his claim." Shrestha, 590 F.3d at 1046.

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