Rincon Bedoya v. Gonzales, No. 06-2785 (unpublished) denies an asylum/CAT petition. The petitioner is a gym teacher from Colombia that spoke out against some political or paramilitary group. It is sustained on affirmed grounds.
A due process argument is advanced. There must be some issue here, but it seems that nobody (i.e. petitioners or the courts) is seriously researching the contours of due process.
The First also briefly discusses Haoud v. Ashcroft, 350 F.3d 201 (1st Cir. 2003), which says that the BIA may not use the affirmance without opinion procedure, 8 C.F.R. § 1003.1(e)(4), without giving due consideration to its own precedents.
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