BIA Must Address Documents About Changed Circumstances

In Zheng v. Mukasey, No. 07-3122, 2008 WL 5006072 (3d Cir. Nov. 26, 2008), the Third Circuit required the BIA to have at least some recognition that it considered the documents that someone submits to support reopening a case due to changed country conditions.

If the BIA does not give some recognition to the submitted documents, the BIA erred and will be overturned.

Fang Dong v. Mukasey (Jan. 6, 2009) (not precedential): BIA failed to recognize all documents submitted to it in a motion to reopen. Third Circuit overturned the BIA.

Lin v. Mukasey (Jan. 6, 2009) (not precedential): same as Fang Dong.

Mei Zhou v. Mukasey (Jan. 6, 2009) (not precedential): similar relevant facts as Fang Dong.

Lyou v. Mukasey (Jan. 7, 2009) (not precedential)

Liu v. Mukasey (Jan. 7, 2009) (not precedential)