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Withholding of Removal is a persecution-related form of relief from deportation, often for people who believe they will be disappeared, tortured, or killed upon a return to their country of origin.
Getting a passport by fraud in a third country to facilitate your departure supports a finding of firm resettlement. I just... Ugh.

Case is Matumona v. Barr.
ca10.uscourts.gov/opinions/18/18…
You must prove that the third country is going to catch onto the fraud?
An absolute railroading of a pro se asylum applicant, getting him to "not contest" DHS's statement that he had become an Angolan citizen.
But he ultimately prevails on one argument, winning remand. But ICE couldn't wait for his appeal of right to be decided and deported him a few months ago. Whoops.

What a travesty.
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