CA5 on Evidence, CAT, Cameroon: Ndifon v. Garland

Ndifon v. Garland

"Elmond Echaukian Ndifon, a native and citizen of Cameroon, petitions for review of the Board of Immigration Appeals’ (“BIA”) decision affirming the Immigration Judge’s (“IJ”) denial of his claim for protection under the Convention Against Torture (“CAT”). Ndifon claims the BIA failed to consider country conditions evidence when separately analyzing his CAT claim. We agree. Consequently, we grant the petition for review and remand for further consideration of the CAT claim."

[Hats off to Joseph Giardina!]