9th Circuit denies review for a Haitian family seeking asylum, upholding an immigration court finding…
Laurant v. Blanche
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9th Circuit denies review for a Haitian family seeking asylum, upholding an immigration court finding that their testimony was not credible.
Why it matters
The Ninth Circuit denied the petition for review filed by Joel Laurant, his wife, and their minor child, all originally from Haiti. The court upheld the immigration agencies' finding that the family was not credible, citing inconsistencies in their testimony and unresponsive answers during hearings. Because their testimony was found not credible and the remaining record was insufficient, the court also upheld the denial of asylum, withholding of removal, and protection under the Convention Against Torture.
Who it affects
- His wife
- Their minor child
What happens next
Current
Decision issued Jul 15, 2026
Unpublished opinion
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- Decision issued Jul 15, 2026Unpublished opinion
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Jul 15, 2026 · Unpublished opinion
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DEEPER READ
Joel Laurant, his wife Betyna Jn Francois Baptiste, and their minor child came before the Ninth Circuit after immigration authorities denied their applications for asylum, withholding of removal, and protection under the Convention Against Torture. The family, natives and citizens of Haiti who had previously lived in Chile, argued they faced persecution and potential torture if returned. The Board of Immigration Appeals had dismissed their appeal of the Immigration Judge's denial, and the family then asked the federal appeals court to review that decision. The central issue was whether the immigration agencies were correct to find the family not credible. The court reviewed both the Immigration Judge's and the Board of Immigration Appeals' decisions under the substantial evidence standard, meaning the agencies' factual findings stand unless no reasonable decision-maker could agree with them. The court found that standard was met here, pointing to repeated nonresponsive answers from the lead petitioner, inconsistencies about when and how the petitioners reported the murder of Laurant's mother, and contradictions regarding a certificate documenting an alleged attack on the family home, which was a key piece of their claim. The family argued that translation difficulties may have caused the apparent evasiveness and inconsistencies in their testimony. The court rejected this explanation, noting that the petitioners asked for clarification from the translator only a small number of times, their attorney never objected to any translation during the hearing, and the transcript showed the family understood and responded appropriately to questioning throughout. Without credible testimony, and with the remaining record insufficient to establish eligibility, the court upheld the denial of asylum and withholding of removal. On the Convention Against Torture claim, the court found that the agencies properly reviewed the objective record evidence and concluded it did not show that torture was more likely than not upon return to Haiti, nor that Haitian authorities would stand by and allow it. The court noted that a government's general inability to investigate or prevent crime is not enough to meet this legal standard. The court found no evidence in the record that would compel a different conclusion, and it denied the petition. There was no dissent noted in the opinion. A previously ordered stay of removal will remain in place only until the court's mandate formally issues.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 15 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT JOEL LAURANT; BETYNA JN No. 25-5306 FRANCOIS BAPTISTE; J. L. L.-J. F. B., Agency Nos. A220-562-879 Petitioners, A220-562-880 A220-562-881 v. TODD BLANCHE, Acting Attorney MEMORANDUM* General, Respondent. On Petition for Review of an Order of the Board of Immigration Appeals Submitted July 10, 2026** Pasadena, California Before: RAWLINSON and SANCHEZ, Circuit Judges, and FITZWATER, District Judge.*** * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). *** The Honorable Sidney A. Fitzwater, United States District Judge for the Northern District of Texas, sitting by designation. Lead petitioner Joel Laurant, native and citizen of Haiti and former resident of Chile, and co-petitioners his wife and minor child petition for review of the Board of Immigration Appeals’ (“BIA’s”) decision dismissing their appeal of the Immigration Judge’s (“IJ’s”) denial of their applications for asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”).1 We deny the petition for review. 1. We have jurisdiction under 8 U.S.C. § 1252. Where, as here, the BIA agreed “with several of the [IJ]’s findings while adding its own reasoning,” we review the decisions of “both the BIA and the [IJ] to the extent that the BIA agreed with the [IJ]’s conclusions.” Flores Molina v. Garland, 37 F.4th 626, 632 (9th Cir. 2022). We review adverse credibility determinations, as well as denials of asylum, withholding, and CAT protection for substantial evidence. See Ani v. Bondi, 155 F.4th 1118, 1126 (9th Cir. 2025). “Under the substantial evidence standard, administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary. . . .” Id. (citation omitted). Substantial evidence supports the agency’s adverse credibility determination. The agency deemed Petitioners not credible because their 1 The child is a derivative beneficiary of Petitioner’s application for asylum under 8 U.S.C. § 1158(b)(3)(A). The child did not file their own application for CAT and withholding of removal and does not have a derivative claim for withholding of removal or CAT relief. See Ali v. Ashcroft, 394 F.3d 780, 782 n.1 (9th Cir. 2005) (withholding of removal and CAT relief “may not be derivative”). 2 25-5306 testimony contained inconsistencies and because Petitioners were unresponsive to questioning. The IJ and BIA cited specific “specific and cogent reasons” based on the record to support the adverse credibility determination. Iman v. Barr, 972 F.3d 1058, 1064 (9th Cir. 2020). The agency’s determination rests on repeated nonresponsive answers by Laurant, inconsistencies in the testimony regarding Laurant’s mother’s time of death and when Petitioners reported her murder, and inconsistencies in Petitioners’ testimony regarding the origin of and explanation for a certificate which documented an alleged attack at the family home that was central to Petitioners’ claims. The agency gave Petitioners sufficient opportunity to explain any evasiveness and inconsistencies, and their explanations do not compel a contrary conclusion. See Li v. Garland, 13 F.4th 954, 961 (9th Cir. 2021). Petitioners argue that difficulties with translation may have contributed to their apparent evasiveness and inconsistent testimony. But, as the BIA noted, Petitioners asked for clarification only a handful of times from the translator as necessary, Petitioners’ counsel never objected to the translation, and the transcript reveals that Petitioners understood and properly responded to the lines of questioning. Given the absence of credible testimony, Petitioners have not demonstrated entitlement to relief for asylum and withholding of removal because “the remaining evidence in the record is insufficient to carry [their] burden of 3 25-5306 establishing eligibility for relief.” Wang v. Sessions, 861 F.3d 1003, 1009 (9th Cir. 2017). 2. Substantial evidence supports the agency’s denial of CAT relief. To qualify for CAT relief, a petitioner must establish that “it is more likely than not that he or she would be tortured if removed to the proposed country of removal.” 8 C.F.R. § 1208.16(c)(2). The agency considered the objective evidence in the record and found it did not demonstrate that Petitioners’ future torture is more likely than not, or that police would acquiesce if notified. See Andrade-Garcia v. Lynch, 828 F.3d 829, 836 (9th Cir. 2016) (stating that “a general ineffectiveness on the government’s part to investigate and prevent crime will not suffice to show acquiescence”). Petitioners point to no evidence in the record that compels a contrary conclusion. PETITION DENIED.2 2 The stay of removal will remain in place until the mandate issues. Petitioners’ motion to stay removal, Dkt. 2, is otherwise denied. 4 25-5306
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