Parmar

MEMORANDUM

Sukhchain Singh Parmar (“Parmar”) petitions for review of the Board of Immigration Appeals’ (“BIA”) affirmance of the Immigration Judge’s (“IJ”) denial of relief based on an adverse credibility finding against Parmar.

Parmar filed his claim for asylum after the effective date of the REAL ID Act, so our review is governed by the Act’s standards for adverse credibility determinations. 8 U.S.C. § 1158 (b)(l)(B)(iii). Inconsistencies in an applicant’s testimony need not go to the heart of his claim, and the IJ may consider many factors in making an adverse credibility determination, including unresponsiveness, inconsistency and demeanor. Id. Here, the IJ and BIA noted that Parmar was unresponsive, especially regarding questions about the arrest and detention that Parmar claimed precipitated his flight from India. There were also inconsistencies in Parmar’s testimony, notably regarding the timing of his third arrest. The IJ’s adverse credibility determination under the REAL ID Act requires a “healthy measure of deference.” Shrestha v. Holder, 590 F.3d 1034, 1041 (9th Cir.2010). The IJ and BIA in this case pointed to specific factors supporting the adverse credibility…