Milanouic v. Holder (7th Cir. Jan. 6, 2010)
ROVNER Manion Wood
The Petitioner had established past persecution in Yugoslavia under the Milosevic regime, but the IJ and BIA found that the Govt had established changed country conditions, rebutting the presumption of future persecution. He argued that local govt officials would still persecute him. The CtApp held, citing Ishitiaq v. Holder, 578 F.3d 712, 717-18 (7th Cir. 2009), that he had an obligation to administratively exhaust specific arguments before raising them at the CtApp; and as he had not done so, his claim failed. The Court also held that it would fail on the merits, since country conditions reports could suffice to rebut a presumption of future harm if they went to the reason the applicant feared returning.