Min Yong Huang v. U.S. Attorney General, No. 13-13285 (11th Cir. 2014)Annotate this Case
Petitioner, a native and citizen of the People's Republic of China, sought review of the BIA's affirmance of the IJ's denial of his petition for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). The court concluded that the BIA's explanation of why it reached the determination that petitioner had not endured past persecution reflects only that it considered his physical harm, not all forms of religious abuse that petitioner suffered. Therefore, the court cannot tell whether the BIA actually took into account the non-physical abuse to petitioner when it rejected his claim of past persecution. Consequently, the court remanded to the BIA to clarify its decision.