Sixth Circuit -- Kassem Hachem v. Eric Holder, Jr.

Immigration - Rule withdrawing voluntary departure upon filing of adverse appeal upheld under Chevron.


ILJ correctly applied totality of circumstances test to adverse credibility finding.


Adversarial demeanor of ILJ insufficiently established to show bias.

Any putative error in finding as to fear of persecution irrelevant, given changed conditions in the country. 

Reinstatement of earlier voluntary departure which had been imposed prior to rulemaking makes the order subject to the rule.


Kassem Hachem v. Eric Holder, Jr.