Khalil v. Garland, No. 23-1443 (1st Cir. 2024)
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In a case involving an Egyptian petitioner, the United States Court of Appeals for the First Circuit reviewed the denial of the petitioner's claim for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) by the Board of Immigration Appeals (BIA). The petitioner, a Coptic Christian and Egyptian citizen, claimed he experienced persecution based on his religion. He was beaten and subjected to demands for conversion to Islam after he refused to alter a sensitive medical test result relating to a Muslim religious leader's family.
The Court found that the BIA failed to correctly apply the "one central reason" test for motive in asylum claims. The Court ruled that the petitioner's religion was at least one central reason for his persecution. The Court also held that the BIA applied the wrong standard of review to the IJ’s conclusion on the petitioner’s CAT claim.
The Court, however, upheld the BIA's conclusion that the petitioner's experiences of verbal harassment and rock-throwing did not rise to the level of persecution. The case was remanded for further proceedings consistent with the Court's opinion.
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