加兰诉戴案

Ming Dai, a Chinese national, sought withholding of removal, claiming a fear of future persecution. An Immigration Judge and the Board of Immigration Appeals found his testimony not credible and denied relief. The Ninth Circuit Court of Appeals overturned this decision, finding Dai s testimony credible and ordering his relief. U.S. Attorney General Merrick Garland, representing the government, appealed to the Supreme Court. The Court ruled unanimously on June 1, 2021, that the Ninth Circuit had erred by improperly engaging in its own fact-finding instead of applying the deferential "substantial evidence" standard required when reviewing agency credibility determinations. The case was remanded for further proceedings consistent with this standard.

The U.S. Supreme Court vacated the Ninth Circuit s judgment. In a unanimous opinion authored by Justice Neil M. Gorsuch, the Court held that the appellate court failed to apply the statutorily required "substantial evidence" standard of review, which mandates deference to agency factual findings unless no reasonable adjudicator could have reached the same conclusion. The case was remanded for the Ninth Circuit to re-evaluate under the correct standard.

The central dispute focused on whether the Ninth Circuit Court of Appeals overstepped its authority by re-evaluating an immigrant s testimony and making its own factual finding of credibility, rather than simply determining if the immigration agency s adverse credibility finding was supported by substantial evidence.

The decision reinforced the strict limits on judicial review of immigration agency decisions, emphasizing that federal appeals courts cannot substitute their own judgment for that of immigration officials on factual matters like witness credibility. This precedent significantly restricts the ability of asylum seekers to successfully challenge adverse credibility determinations on appeal, solidifying the power of immigration judges and the Board of Immigration Appeals in making final factual findings.