Satnam Singh v. Eric Holder, Jr.

MEMORANDUM

Santam Singh, an Indian national, petitions for review of the Board of Immigration Appeals’ (“BIA”) order affirming the Immigration Judge’s (“IJ”) decision declaring his asylum application frivolous. Petitioner claims that the BIA’s affirmance was error, because Petitioner did not make a deliberate misrepresentation due to inef fective assistance of counsel, and because Petitioner received inadequate notice of his right to counsel. These arguments lack merit.

First, Petitioner concedes that he knew the statements in his asylum application and interview were false when made. Petitioner’s argument that his lawyer told him to lie thus only explains why he lied, rather than suggest that his lies were unknowing or involuntary. Second, the asylum application signed by Petitioner contained written warnings that adequately notified him “of both the consequences of knowingly filing a frivolous application for asylum as well as the privilege of being represented by counsel, as required by 8 U.S.C. § 1158 (d)(4)(A).” Cheema v. Holder, 693 F.3d 1045, 1049 (9th Cir.2012).

PETITION DENIED.

This disposition is not appropriate for publication and is not precedent except as provided…