context: Perhaps Dosa viewed the bribery of even sympathetic colonels as something one takes for granted as a prison escapee in Togo. Perhaps he was worried about declaring on a government form that he had been involved in bribing an official. We will never know. I do not believe, however, that the IJ's inferences that the bribery never took place, and that Dosa's credibility was undermined by his claim that it did, were so self-evident that the IJ was warranted in relying on them without any explanation.
citation_a.signal: see
citation_a.identifier: 331 F.3d 308, 308
citation_a.parenthetical: "If minor inconsistencies or misrepresentations of unimportant facts cannot constitute the basis for an adverse credibility finding, a fortiori minor omissions cannot."
citation_a.sentence: See Lam v. Ashcroft, 112 Fed.Appx. 477, 479 (6th Cir.2004) (unpublished) (“Courts have diminished the significance of omissions when an applicant testifies at a hearing about something that is left out of his initial application because of the limited space available on the application forms.”) (citing Secaida-Rosales v. INS, 331 F.3d 297, 308-09 (2d Cir.2003)); Secaida-Rosales, 331 F.3d at 308 (“If minor inconsistencies or misrepresentations of unimportant facts cannot constitute the basis for an adverse credibility finding, a fortiori minor omissions cannot.”); see also Hartooni v. INS, 21 F.3d 336, 342 (9th Cir.1994) (IJ must offer a “specific, cogent reason for any stated disbelief.”).
citation_b.signal: see also
citation_b.identifier: 21 F.3d 336, 342
citation_b.parenthetical: IJ must offer a "specific, cogent reason for any stated disbelief."
citation_b.sentence: See Lam v. Ashcroft, 112 Fed.Appx. 477, 479 (6th Cir.2004) (unpublished) (“Courts have diminished the significance of omissions when an applicant testifies at a hearing about something that is left out of his initial application because of the limited space available on the application forms.”) (citing Secaida-Rosales v. INS, 331 F.3d 297, 308-09 (2d Cir.2003)); Secaida-Rosales, 331 F.3d at 308 (“If minor inconsistencies or misrepresentations of unimportant facts cannot constitute the basis for an adverse credibility finding, a fortiori minor omissions cannot.”); see also Hartooni v. INS, 21 F.3d 336, 342 (9th Cir.1994) (IJ must offer a “specific, cogent reason for any stated disbelief.”).