Matter of E-N-N-
29 I&N Dec. 586 (BIA 2026)
2026
Holding
(1) IJ clearly erred finding respondent credible without addressing inconsistencies and implausibilities in the record. (2) IJ's conclusory finding of a pattern or practice of persecution against Anglophones in Cameroon was not supported by record evidence, particularly given the IJ did not distinguish the respondent's family members who remain unharmed in the country.
Practitioner Note
A pattern-or-practice finding requires individualized analysis. Family members living unharmed in the same country substantially undercuts such findings.
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