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Cite as 29 I&N Dec. 586 (BIA 2026) 	Interim Decision #4185
Matter of E-N-N-, Respondent
Decided by Board March 20, 20261
U.S. Department of Justice
Executive Office for Immigration Review
Board of Immigration Appeals
(1) The Immigration Judge clearly erred in finding the respondent credible without
addressing inconsistencies and implausibilities that were present in the record.
(2) The Immigration Judge’s conclusory statement that there is a pattern or practice of
persecution against Anglophones in Cameroon was not supported by record evidence,
particularly given the Immigration Judge did not distinguish the respondent’s family
members, who remain unharmed in the country.
FOR THE RESPONDENT: Fedelis N. Fondungallah, Esquire, Avondale, Arizona
FOR THE DEPARTMENT OF HOMELAND SECURITY: 	Jessie Sizemore, Assistant
Chief Counsel
BEFORE: 	Board Panel: 	GEMOETS and CHABAN, Appellate Immigration Judges;
GILLIES, Temporary Appellate Immigration Judge.
GEMOETS, Appellate Immigration Judge:
The Department 	of 	Homeland 	Security (“DHS”) appeals 	from 	the
decision of the Immigration Judge dated June 25, 2025, granting withholding
of removal to the respondent, a native and citizen of Cameroon. 	Section
241(b)(3)(A) of the Immigration and Nationality Act (“INA”), 8 U.S.C.
§ 1231(b)(3)(A) (2024). The respondent opposes the appeal. The appeal will
be sustained and the record remanded.
On appeal, DHS argues the Immigration Judge clearly erred in her
favorable credibility determination. 	See 8 C.F.R. § 1003.1(d)(3)(i) (2026).
We 	agree. 	DHS 	has 	pointed 	out 	numerous 	inconsistencies 	and
implausibilities that were not addressed by the Immigration Judge. See INA
§§ 	208(b)(1)(B)(iii), 	241(b)(3)(C), 	8 	U.S.C. 	§§ 	1158(b)(1)(B)(iii),
1231(b)(3)(C) (2024) (setting forth standard for credibility determinations).
1 	Pursuant to Order No. 6744-2026, dated April 21, 2026, the Acting Attorney General
designated the Board’s decision in Matter of E-N-N- (BIA Mar. 20, 2026), as precedent in
all proceedings involving the same issue or issues. See 8 C.F.R. § 1003.1(g)(3) (2026).
Editorial changes have been made consistent with the designation of the case as a
precedent.

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For instance, the Immigration Judge failed to explain whether the medical
evidence is reliable when there are clear errors in the documents and the
respondent failed to provide a plausible explanation. 	Furthermore, notable
inconsistencies include the name of the hospital where treatment was
provided, what treatment the respondent received, and what weapons caused
his injuries that were purportedly produced by government officials beating
him during prolonged detention. The Immigration Judge simply states that
she finds the respondent to be a credible witness without providing any
further evaluation.2 	This is clear error and requires further evaluation on
remand. 8 C.F.R. § 1003.1(d)(3)(i).
We also find legal error in the Immigration Judge’s determination that the
respondent has proven there is a pattern or practice of persecution for those
who are considered Anglophone in Cameroon. See Matter of A-M-, 23 I&N
Dec. 737, 740–42 (BIA 2005); 8 C.F.R. § 1003.1(d)(3)(ii). The Immigration
Judge 	again 	provides 	only 	a 	conclusory 	statement 	without 	providing
adequate 	rationale 	to 	explain 	the 	determination. 	Specifically, 	the
Immigration Judge has not explained why the respondent’s independent
evidence outside of his noncredible testimony would establish a pattern or
practice such that he has met his burden to establish that his life or freedom
would 	be 	threatened. 	See 	8 	C.F.R. 	§ 	1208.16(b)(2)(i), 	(ii) 	(2026).
Additionally, 	the 	Immigration 	Judge 	uses 	an 	incorrect 	standard 	by
concluding 	that there 	is a “likelihood” that the respondent would be
persecuted or harmed simply based on his race. 	This is not the correct
standard for withholding of removal, which requires a “clear probability” or
“more likely than not” standard to be met. See INS v. Stevic, 467 U.S. 407,
424 (1984); Sanchez-Castro v. U.S. Att’y Gen., 998 F.3d 1281, 1286 (11th
Cir. 2021).
Further, the Immigration Judge determined that the respondent meets the
standard for a pattern or practice of persecution despite some of his family
members remaining in Cameroon without being persecuted or harmed.
However, where similarly situated family remains unharmed in the country,
the claim may be undermined. See 8 C.F.R. § 1208.16(b)(2)(i); Suwarjo v.
U.S. Att’y Gen., 274 F. App’x 794, 797 (11th Cir. 2008); Candra v. U.S. Att’y
2 	A respondent’s credibility is an ancillary factor relevant to an Immigration Judge’s
ultimate decision and requires an Immigration Judge’s analysis and findings to permit clear
error review on appeal. See INA § 240(c)(4)(B); 8 U.S.C. § 1229a(c)(4)(B) (2024); see
also 8 C.F.R. § 1003.1(d)(3)(i). Accordingly, the Immigration Judge erred by failing to
provide clear credibility findings. See Matter of M-S-, 21 I&N Dec. 125, 129 (BIA 1995)
(holding that a persecution claim that lacks veracity cannot satisfy burdens of proof
necessary to establish eligibility for asylum and withholding of removal).

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Gen., 222 F. App’x 865, 870–71 (11th Cir. 2007). 	Here, the respondent’s
mother, siblings, and child remain in Cameroon and have not been harmed
despite also being Anglophones. The Immigration Judge’s decision provides
no basis or explanation to distinguish the respondent’s family members from
himself. Further analysis and explanation is necessary on remand.
On remand, both parties may also submit additional evidence and
arguments relevant to these applications for relief and protection, or any
other relief based on current case law. Our decision to remand the record to
the Immigration Judge should not be construed as indicating an opinion on
the ultimate resolution of the respondent’s case. 	See generally Matter of
L-O-G-, 21 I&N Dec. 413, 422 (BIA 1996).
ORDER: The appeal is sustained, and the record is remanded for further
proceedings consistent with the foregoing opinion and entry of a new
decision.