National Immigrant Justice Center
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TCHITCHUI V. HOLDER
2nd Circuit
Tchitchui v. Holder (2nd Cir., Sept. 19, 2011)
Cabranes, Raggi, Restani (per curiam)
Summary: The Second Circuit affirmed the agency’s denial of the Cameroonian petitioner’s application for asylum, finding that based on the totality of the circumstances he had firmly resettled in Guatemala where he had lived for a number of years and owned multiple businesses before his ultimate travels to the United States. The Court determined that petitioner did not rebut the Government’s prima facie evidence of resettlement as he could not satisfy the three prong exception under 8 C.F.R. § 208.15(a).
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