More non-precedential decisions on asylum claims

Ndreu v. Attorney General, No. 04-2006 (3d Cir. May 12, 2005) (non-precedential): affirmed the IJ's denial of an asylum claim by someone from Albania because post-1992 incidents were not persecution and pre-1991 incidents can be set aside because of changed country conditions. The IJ felt that post-1992 incidents including a carjacking lacked proof they were because of political reasons due to the total anarchy in Albania in 1997. Also, the asylum seeker never sought medical attention and did not receive death threats so the trauma was not sufficiently severe to constitute persecution. As far as pre-1992 incidents, times have changed in Albania and now the opposition party has access to the media and has run in elections.

Manan v. Attorney General, No. 04-2430 (3d Cir. May 12, 2005) (non-precedential): affirmed the IJ's denial of asylum or other relief by someone who fought the Taliban in Afghanistan. The BIA held that the Taliban has fallen in Afghanistan and there is little threat from the remaining bands of Taliban militia there.