In a short but sweet disposition, the Sixth Circuit disagreed with the Board of Immigration Appeals' denial of a motion to reopen based on changed country conditions.  Uwineza, a citizen of Rwanda, submitted several emails from friends in Rwanda that indicated that government officials were looking for her because they believed she supported an opposition political figure.  The Board discredited the emails because they were unsworn and came from interested witnesses who were not subject to cross-examination.  The Sixth Circuit rejected this decision, deeming the Board's decision to be devoid of rational explanation.  "The new evidence appears to satisfy the requirements of not having been previously available and indicating a change in conditions in Rwanda material to Uwineza’s claim. The BIA rejected the evidence on the ground that the letters were unsworn and appeared to have been written in support of her case, which we have found invalid. The BIA also noted that the letters were from interested witnesses, but interested witnesses would normally be expected to have information relevant to a petitioner’s claim, and that the witnesses were not subject to cross-examination, which will also normally be the case in a motion to reopen."

The full text of Uwineza v. Holder can be found here: