Case Explained: Ntwari v. Bondi

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-14 The Tenth Circuit denied Brunel Ntwari’s petition for review of the Board of Immigration Appeals’ decision affirming an immigration judge’s denial of his applications for asylum, withholding of removal, and protection under the Convention Against Torture. The court applied the substantial evidence standard to review the agency’s factual findings, requiring that the petitioner demonstrate the evidence presented was so compelling that no reasonable factfinder could have reached the agency’s conclusion. The court rejected Ntwari’s arguments on two primary grounds. First, it held that it could not consider new affidavits submitted after the BIA decision because judicial review is strictly limited to the administrative record on which the removal order is based under 8 U.S.C. § 1252(b)(4)(A). Second, the court found the BIA did not err by treating the lack of corroboration as dispositive despite finding Ntwari generally credible; the immigration judge reasonably determined that Ntwari’s testimony contained implausibilities and inconsistencies, rendering it insufficient to meet his burden of proof without additional evidence. As a result of this denial, the order of removal issued by the immigration judge remains in effect, and Ntwari is subject to deportation. The court granted his motion to proceed on appeal without prepayment of costs or fees but affirmed the agency’s decision denying relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.