In the Matter of C-T-L
IRLI, on behalf of its client the Federation for American Immigration Reform (FAIR), submitted a friend-of-the-court brief at the request of the Board of Immigration Appeals (BIA) to address the burden of proof required for aliens who have filed a Withholding of Removal (WOR) petition and primarily whether the “one central reason” standard had any effect on the burden of proof required for WOR. IRLI established that the “once central reason” standard did not apply to withholding of removal claims. IRLI argued that the REAL ID Act of 2005 had no effect on the WOR standard either expressly or implicitly. While the REAL ID Act did raise the burden of proof required for asylum claims, it did not raise the burden of proof required for WOR claims. IRLI noted that historically, WOR placed a more stringent burden on applicants. IRLI also highlighted the importance of keeping the two types of relief, asylum and WOR, distinct.