Zheng v. Holder

Ct. of Appeals remanded for further consideration alien’s asylum and withholding of removal applications where alien (native of China) alleged that she would be subjected to forced sterilization if required to return to China, under circumstances where alien already had two U.S.-born children. While Bd.’s denial was based on 2007 Country Profile that suggested China was barring use of physical coercion to compel persons to submit to forced abortion or sterilization, other more recent documents suggested that Chinese Fujian authorities were more vigorously enforcing one-child policy and applied it even in circumstances where children were born outside of China.