A year and a half ago I wrote about a January 26, 2012, Ninth Circuit Court of Appeals decision in Oshodi v. Holder (Oshodi I). The case presented an intra-circuit split on the issue of when an alien must provide corroborating evidence in an asylum hearing. An earlier Ninth Circuit case, Ren v. Holder, held: Therefore, the IJ must undertake the following sequential analysis. To begin, the IJ must determine whether an applicant’s credible testimony alone meets the applicant’s burden…

On January 26, 2012, the Ninth Circuit filed a decision, Oshodi v. Holder, which seems to have reversed another Ninth Circuit case, Ren v. Holder, filed on August 19, 2011.    The issue in the case was corroboration of testimony in an asylum, withholding, and Convention Against Torture case. These are cases where people ask to stay in the United States because they are afraid to go home – either because they fear persecution on account of their race, religion, political…