CHEN’s Empirical Analysis
1989
Citation profile
47 federal appellate ·
How this case has been cited
Cited by 180 later decisions — most recently April 2025 · most notably Shi Liang Lin v. United States Department of Justice (2007), Rusu v. U.S. Immigration & Naturalization Service (2002)
47 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 8 U.S.C. § 1101 (§ 101 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1158 (§ 208 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1251 (§ 241 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1253 (§ 243 of the Immigration and Nationality Act of 1952 (McCarran-Walter))
Relies on Immigration & Naturalization Service v. Cardoza-Fonseca · Immigration & Naturalization Service v. Stevic · Desir v. Ilchert · Blanco-Comarribas v. Immigration & Naturalization Service · Guevara Flores v. Immigration & Naturalization Service
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 180 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[e]ven though there may have been a change of regime in his country, this may not always produce a complete change . . . in view of his past experiences, in the mind of the refugee.”
3 later decisions quote this exact passage“If an alien establishes that he has been persecuted in the past ... he is eligible for a grant of asylum. The likelihood of present or future persecution then becomes relevant as to the exercise of discretion, and asylum may be denied as a matter of discretion if there is little likelihood of present persecution.”
2 later decisions quote this exact passage“the Service ordinarily will have to present, as a factor militating against the favorable exercise of discretion, evidence that there is little likelihood of present persecution.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.