Mutuku 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 an issue was exhausted, even though not presented to the BIA, because petitioner argued it before the IJ and the BIA adopted the IJ’s decision citing Matter of Burbano, 20 I. & N. Dec. 872, 874 (BIA 1994)
• “Where an issue has been presented to the IJ, and the BIA affirms the IJ decision . . . , the issue is deemed exhausted.”
• issue is properly exhausted when it was presented to the IJ, and the BIA affirmed citing Matter of Burbano
• “We review factual findings regarding changed country conditions for substantial evidence.”

Source: CourtListener parenthetical corpus (CC0).