## Facts

- S-M-J-, a Liberian citizen, sought asylum and withholding after being paroled into the United States following evacuation from Zaire.
- She had lived in Zaire since 1987 with an uncle described as the Liberian ambassador to Zaire.
- She claimed fear of returning to Liberia based on reports that her father’s house was burned and that her father was “governor” of the Vai tribe.
- She asserted a separate fear based on a family relationship to an individual named Prince Anderson but provided minimal identifying information or explanation of why the relationship created risk.
- The record contained limited supporting documentation and did not meaningfully explain key contextual facts (e.g., the Vai tribe’s position in Liberia, the significance of her father’s role, or Prince Anderson’s identity).
- The Immigration Judge denied asylum and withholding for insufficient proof; S-M-J- appealed to the Board of Immigration Appeals.

## Issues

1. Whether the applicant met her burden to establish eligibility for asylum and withholding on the existing, limited record.
2. When an asylum applicant must provide corroborating evidence for alleged, material facts, even if testimony is credible.
3. What responsibilities the Immigration Judge and the government have to develop and place country-conditions and other background evidence into the record, including disclosure of any extra-record knowledge relied upon.

## Decision

- The BIA did not grant or deny relief on the merits; it found the record inadequately developed for proper adjudication under clarified evidentiary standards.
- The BIA held that general country-conditions information, where available, must be placed in the record as a foundation for evaluating the claim.
- The BIA held that corroboration is required when it is reasonable to expect it and the evidence is reasonably obtainable; otherwise, the applicant must provide an adequate explanation for its absence.
- The BIA stated the government should play an active role in introducing evidence regarding current country conditions.
- The BIA required that if the Immigration Judge relies on country-conditions knowledge central to the claim, the source materials must be made part of the record.
- The case was remanded for further proceedings and record development consistent with these standards.

## Legal Principles

- The applicant bears the burden of proof for asylum and withholding, which may include providing corroboration of material facts when such evidence is reasonably obtainable.
- Credible testimony may be insufficient where it is reasonable to expect documentation (or similar supporting evidence) for key, claim-specific facts and no adequate explanation is given for its absence.
- Adjudicators must not impose unreasonable corroboration demands, including demands for evidence that is practically unobtainable.
- General background country-conditions information, where available, must be included in the administrative record to allow reasoned evaluation and appellate review.
- The government should actively introduce current country-conditions evidence rather than leaving the record wholly to the applicant.
- Any country-conditions sources relied upon by the Immigration Judge must be identified and placed in the record when central to the decision.

## Conclusion

The BIA remanded because the record lacked necessary country-conditions and claim-specific support, and it established that asylum adjudication requires a developed record: applicants must reasonably corroborate material facts or explain nonproduction, the government should help supply country evidence, and Immigration Judges must disclose on-record any country-information sources they rely upon.


In re S-M-J-, 21 I. & N. Dec. 722 (B.I.A. 1997) (en banc)