Zuo Zhang v. Loretta E. Lynch

MEMORANDUM *** '

Zuo Chen Zhang petitions for review of the Board of Immigration Appeals’ (BIA) order (1) dismissing his appeal from the immigration judge’s (IJ) denial of his application for asylum, withholding of removal, and relief under the Convention Against Torture (CAT); and (2) denying his motion to remand. We deny Zhang’s petition in part and dismiss it in part.

1. We need not decide whether the REAL ID Act of 2005 applies here. The BIA decided the case, in the alternative, under both pre- and post-REAL ID Act standards. Even under pre-REAL ID standards, Zhang has not established that…