Huo Qiang Chen v. Holder

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that threats alone do not constitute past persecution
• explaining 11 that, generally, “threats of persecution, no matter how credible, do not 12 demonstrate past persecution”
• “Because the standard for withholding of 7 removal is thus more demanding than that for asylum, it necessarily follows that 8 an alien who cannot demonstrate eligibility for asylum also cannot demonstrate 9 entitlement to withholding of removal.”
• unfulfilled threats 5 are generally insufficient to establish past persecution

Source: CourtListener parenthetical corpus (CC0).