Camara v. Holder, No. 11-4043 (6th Cir. 2013)
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Petitioners are citizens of Mali who remained in the U.S. longer than authorized under their visitors’ visas. In 2006, Camara sought asylum and withholding of removal based on past persecution she suffered in the form of female genital mutilation (“FGM”); she listed her husband as a derivative applicant. She testified that she was unable to submit her asylum application by the one-year filing deadline because she and her husband had experienced medical problems. The IJ denied Petitioners’ applications, finding that Camara’s FGM constituted past persecution; however, he found that even if Camara’s illness was an “extraordinary circumstance” sufficient to excuse the filing deadline, Camara had failed to show she filed within a reasonable period. On remand, the IJ again rejected the applications. The Board of Immigration Appeals affirmed, finding Kalle removable because: Camara’s lead asylum application was denied; Kalle never applied for individual relief; and withholding of removal is not available derivatively. The Sixth Circuit denied review, rejecting arguments that Kalle was denied due process when the Board failed to consider evidence of his intent to apply for individual withholding of removal and that withholding of removal ought to be available derivatively.
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