The Third Circuit has overturn a two phrase negative fear determination, finding that it is insufficient for appellate review. The Immigration Judge decision stated, ““R not targeted on account of protected ground. Government is willing to assist.”
“A two-sentence recitation on a bulletpoint form will rarely, if ever, provide sufficient reasoning for a decision. A decision, such as the one here, that does not refer to record evidence will never suffice.”
The full text of Valarezo-Tirado v. Attorney General can be found here:
https://www2.ca3.uscourts.gov/opinarch/201705pa.pdf
An amended decision can be found here: