Case Citator › Rizk v. Holder

Rizk v. Holder

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Ninth Circuit
Citation
629 F.3d 1083
Decided
Confirmed treatments
1
Flagged citations read
53 of 53
Citing cases (total)
53
Treatment dates
2021
Overruled in part
A reviewed court has overruled part of this case’s holding. Rizk v. Holder was overruled in part. The Ninth Circuit's en banc decision in Alam v. Garland overruled Rizk's rule that one supported reason is enough to sustain an adverse credibility finding.
More on how this was screened

Peng Shen v. Garland later identified Rizk as overruled on that point. Alam did not address Rizk's separate requirement that an asylum applicant have an opportunity to explain an apparent inconsistency. All 53 flagged citations have been read; the confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

53 later cases cite Rizk v. Holder; 53 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Rizk v. Holder?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Ninth Circuit overruled Rizk's single factor rule for reviewing adverse credibility findings.

    Alam v. Garland · Ninth Circuit (en banc) · filed

    On rehearing en banc, we hold that the single factor rule conflicts with the REAL ID Act of 2005, Pub. L. No. 109-13, 119 Stat. 231 (2005), and we overrule our prior precedent establishing and applying it.
    Read the full opinion on CourtListener →

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