BIA Denies Protection for Georgian Political Activist: Matter of G-C-I- (2025)
Authority: Board of Immigration Appeals (BIA), precedent decision
Key takeaway: If an immigrant gives inconsistent or evasive testimony, and fails to provide supporting evidence, immigration judges can deny asylum, withholding of removal, and CAT protection.
The Story
The respondent, a man from Georgia (the country, not the U.S. state), claimed he was persecuted for supporting the United National Movement (UNM), an opposition political party.
He told the court that:
- He was beaten by police in 2020 while transporting people to vote.
- After seeking asylum in France unsuccessfully, he returned home.
- He was again beaten by police during a 2024 rally and later fled to the United States.
He asked for withholding of removal (a protection that blocks deportation if returning home would likely mean persecution) and Convention Against Torture (CAT) protection.
The Judge’s Decision
The Immigration Judge denied his requests. The judge found:
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He was not a credible witness.
- His testimony about when he joined the UNM conflicted with earlier statements (2005 vs. 2015).
- Some parts of his story seemed implausible, like being recognized by police in the dark at a massive rally.
- He gave evasive answers when asked why he couldn’t provide medical records or evidence.
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He lacked corroborating evidence.
- He only provided general news articles about unrest in Georgia.
- He failed to get medical records from his hospital visits.
- He didn’t even submit a letter from his brother—who lives in the U.S. and was central to his political activities.
Because of this, the judge said he did not meet his burden of proof.
The BIA’s Ruling
On appeal, the BIA agreed with the judge and dismissed the case. Here’s what they emphasized:
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Credibility matters.
- An applicant must prove their own credibility.
- Inconsistent, implausible, or evasive answers undermine credibility.
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Corroboration matters.
- Even if someone is credible, they usually still need documents or testimony to back up their claims.
- Failure to provide reasonably available evidence—like medical records or family letters—can independently sink a case.
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Country conditions aren’t enough.
- General reports of human rights abuses don’t prove that this specific person faces torture or persecution.
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No CAT protection.
- The respondent didn’t provide evidence showing he personally was at risk of torture.
- Without individualized proof, general violence in Georgia wasn’t enough.
Outcome
- Appeal dismissed.
- Applications for withholding of removal and CAT protection denied.
- The respondent was left with a final order of removal back to Georgia.
The BIA also noted that failure to comply with the removal order could result in civil fines of up to $998 per day.
Why This Case Matters
- For immigrants: You must be consistent and detailed in your testimony. Even small contradictions can damage your case.
- For lawyers: Credibility and corroboration are separate but equally critical. A client’s story alone usually isn’t enough—supporting documents are vital.
- For the system: This case reinforces that general reports of violence or abuse in a country don’t guarantee protection. The law demands personalized proof of danger.
Bottom Line
In Matter of G-C-I- (2025), the BIA ruled that without consistent testimony and corroborating evidence, a claim of political persecution cannot succeed. The case highlights a harsh reality in immigration law: credibility plus proof is required to win relief.
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