The Board of Immigration Appeals has sustained DHS's appeal from a grant of asylum to a family from Burkina Faso, whose claim rested on the lead respondent's account of his service in the presidential security regiment. The respondent had twice denied any military service on visa applications years earlier, and the immigration judge found this indicative of a propensity for dishonesty but nonetheless deemed him credible because he was forthright in admitting he had lied.
The Board held that this reasoning was clearly erroneous, since candor about a documented history of lying to obtain immigration benefits does not, by itself, establish present credibility. The Board also found that the immigration judge did not adequately address inconsistencies undermining the respondent's explanation for the earlier falsehoods, failed to make an explicit credibility finding as to a corroborating witness who gave false testimony about a pending arrest warrant, and did not sufficiently analyze whether the documentary evidence corroborated the specific details of the claimed persecution. The case was remanded for a fuller credibility and corroboration analysis.
The full text of Matter of T-D-E- can be found here: https://www.justice.gov/eoir/media/1450076/dl?inline