Vatulev v. Ashcroft’s Empirical Analysis
354 F.3d 1207 · 2003
Citation profile
16 federal appellate ·
How this case has been cited
Cited by 99 later decisions — most recently January 2026 · most notably Uanreroro v. Gonzales (2006), Hang Kannha Yuk v. Ashcroft (2004)
16 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))
Relies on Hoxha v. Ashcroft · Molina-Estrada v. Immigration & Naturalization Service · Melencio Legui Lim v. Immigration and Naturalization Service · Singh v. Immigration & Naturalization Service · Ouda 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 99 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Generally speaking, an alien may not be removed to a particular country if he or she can establish a clear probability of persecution in that country on the basis of race, religion, nationality, membership in a particular social group, or political opinion. Persecution is the infliction of suffering or harm upon those who differ (in race, religion, or political opinion) in a way regarded as offensive, and requires more than just restrictions or threats to life and liberty. Such persecution may be inflicted by the government itself, or by a non-governmental group that the government is unwilling or unable to control.”
1 later decision quote this exact passage · from the majority“There are three ways to establish refugee status, two of which are pertinent here: One way is by showing [the applicant] has a well-founded fear of future persecution. A second way is by establishing that he or she has suffered past persecution, which gives rise to a [rebut-table] presumption that he or she has a well-founded fear of future persecution. The persecution involved must be on account of [the applicant’s] race, religion, nationality, membership in a particular social group, or political opinion, and must be imposed by the government or by groups which the government is unwilling or unable to control.”
1 later decision quote this exact passage · from the majority“our review is limited, in breadth, to that threshold determination. Our review is further limited, in depth, to evaluating whether the record on the whole provides substantial support for that determination or, rather, is so decisively to the contrary that a reasonable factfinder would have concluded petitioner is a refugee.”
1 later decision quote this exact passage · from the majority
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.