Trifoni v. Holder

4 Citing cases

  1. Mbonga v. Garland

    18 F.4th 889 (6th Cir. 2021)   Cited 14 times
    Noting that Court "generally may not address an issue that the Board did not reach"

    After those governments lost power, however, asylum applicants who previously suffered abuse at their hands could not show that they reasonably feared future abuse from the new government. See, e.g. , Trifoni v. Holder , 351 F. App'x 19, 23–24 (6th Cir. 2009) ; Ndrecaj v. Mukasey , 522 F.3d 667, 676–77 (6th Cir. 2008) ; Ramaj , 466 F.3d at 531 ; Lakaj v. Gonzales , 158 F. App'x 678, 682 (6th Cir. 2005). This governmental change instead switched the burden to the Albanian asylum applicants to explain why they had a continued fear of persecution.

  2. Shafo v. Wilkinson

    No. 19-4143 (6th Cir. Jan. 25, 2021)   Cited 7 times

    Like the Board, we conclude that she failed to show prejudice. See Trifoni v. Holder, 351 F. App'x 19, 25 (6th Cir. 2009). To establish prejudice in this immigration setting, an immigrant must show that an alleged due-process violation "led to a substantially different outcome" from what would have resulted without the violation.

  3. Ashafi v. Holder

    418 F. App'x 447 (6th Cir. 2011)   Cited 2 times

    This finding aligns with a laundry list of decisions by this court recognizing that changed political circumstances prevent once-persecuted Albanians from now seeking asylum. See, e.g., Preducaj v. Holder, 379 Fed.Appx. 508, 511 (6th Cir. 2010); Trifoni v. Holder, 351 Fed.Appx. 19, 23 (6th Cir. 2009); Maklaj v. Mukasey, 306 Fed.Appx. 262, 264 (6th Cir. 2009). Resisting this conclusion, Ashafi argues that while the political situation in Albania has improved, his personal fear of persecution has not.

  4. Preducaj v. Holder

    379 F. App'x 508 (6th Cir. 2010)   Cited 3 times

    Indeed, we have consistently upheld determinations of changed country conditions in Albania based on an identical showing. See, e.g., Trifoni v. Holder, 351 Fed.Appx. 19 (6th Cir. 2009); Maklaj v. Mukasey, 306 Fed. Appx. 262 (6th Cir. 2009); Lumaj v. Gonzales, 193 Fed.Appx. 557 (6th Cir. 2006). Preducaj is ineligible for asylum.