CA1: Haiti getting better

Michel v. Mukasey, No. 07-2166 (7/28/08) (unpublished) denies a petition for review of an asylum application.  The First says that his past persecution really isn’t that relevant has Haiti is a really awesome place, but in a “general state of disarray.”  Or, in the words of a per curiam court (must likely Judge Selya), “With the levers of power having been wrested from the hands of his antagonists, there is no realistic possibility that the petitioner's pro-Convergence sympathies will place him in the Haitian government's cross-hairs.”

The petitioner appeared to be making a more developed argument about how exactly the BIA should review an IJ, but I don’t think it was taken that seriously.