Ibrahim Mwangi v. William P. Barr

LOKEN, Circuit Judge.

Ibrahim Mwangi, a citizen of Kenya, was admitted to the United States in 1998 and overstayed his student visa. After his fourth arrest for driving under the influence, the Department of Homeland Security (DHS) commenced removal proceedings. Mwangi applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT), alleging fear he would be killed if he returned to Kenya "because of owning land" and because he belonged to the Kikuyu tribe.

After a hearing, the immigration judge (IJ) ordered Mwangi removed to Kenya; the Board of Immigration…