Matter of T-D-E-

BIA

29 I&N Dec. 732 (BIA 2026)

2026

Holding

An IJ may not determine that a respondent is credible solely because the respondent was candid in admitting he previously lied to obtain immigration benefits.

Practitioner Note

Candor about prior deception is not a substitute for overall credibility. An IJ must assess the totality of the circumstances and may not bootstrap a credibility finding from an admission of past fraud.

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