In an unpublished decision, the Ninth Circuit recognized the difficulty of testifying about trauma and reversed an adverse credibility determination for a victim of domestic violence seeking asylum.
"[T]he circumstances of Ortiz’s testimony make the asserted inconsistencies only minimally probative of her credibility. At both her reasonable fear interview and at her hearing before the IJ, Ortiz testified without counsel, through an interpreter, and about very traumatic subjects. It is likely that the inconsistencies identified by the BIA were the products not of untruthfulness, but of misunderstanding, mistake, or bad memory. Considering the record as a whole, the 'totality of the circumstances, and all relevant factors,' we hold that the BIA’s adverse credibility determination was not supported by substantial evidence."
The full text of Ortiz-Ortiz v. Sessions can be found here:
https://cdn.ca9.uscourts.gov/datastore/memoranda/2017/06/09/14-73863.pdf