Pair of unpublished asylum decisions

http://www.ca6.uscourts.gov/opinions.pdf/09a0742n-06.pdf
http://www.ca6.uscourts.gov/opinions.pdf/09a0744n-06.pdf

In this pair of unpublished decisions, the court affirmed the BIA's denial of asylum and withholding of removal.  In Toure, the court rejected one of the two reasons given in support of an adverse credibility finding.  The court found that an inconsistency relating to whether the alien sign or did not sign a document stating that he was not tortured is "minor and irrelevant" and was not used to enhance his claim.  Nevertheless, the court was highly deferential to the Immigration Judge's conclusion and upheld the adverse credibility determination after rejecting half of the basis for that determination.

Both decisions discuss the level of harm necessary to show persecution.