Malak Manes v. Jefferson Sessions, 875 F.3d 1261 (9th Cir. 2017). · Go Syfert
Malak Manes v. Jefferson Sessions, 875 F.3d 1261 (9th Cir. 2017). Cases Citing This Book View Copy Cite
154 citation events (154 in the last 25 years) across 1 distinct court.
Strongest positive: Siyang Xiang v. Merrick Garland (ca9, 2022-01-27)
Treatment trajectory · 2017 → 2026 · click a year to view as-of
2017 2021 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Siyang Xiang v. Merrick Garland (3×) also: Cited "see"
9th Cir. · 2022 · signal: see · quote attribution · 2 verbatim quotes · confidence high
because credibility determinations are findings of fact by the ij, they are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.
discussed Cited as authority (verbatim quote) Zhirayr Lalayan v. Merrick Garland
9th Cir. · 2021 · signal: see also · quote attribution · 1 verbatim quote · confidence high
these are specific, first-hand observations-precisely the kind of credibility cues that are the special province of the factfinder.
discussed Cited as authority (rule) Ndiaye v. Blanche
9th Cir. · 2026 · confidence medium
The agency was therefore “permitted to afford substantial weight to inconsistencies that ‘[bore] directly on [the petitioner’s] claim of persecution.’” Rodriguez-Ramirez v. Garland, 11 F.4th 1091 , 1093 (9th Cir. 2021) (quoting Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam)) (citation modified).
discussed Cited as authority (rule) Montejo Esteban Lucas v. Pamela Bondi
9th Cir. · 2026 · confidence medium
“This inconsistency bears directly on [Esteban Lucas’s] claim of persecution, thereby permitting the [BIA and IJ] to afford it substantial weight.” See Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Ceron Santos v. Bondi
9th Cir. · 2025 · confidence medium
See Rodriguez-Ramirez v. Garland, 11 F.4th 1091 , 1094 (9th Cir. 2021) (per curiam) (holding that substantial evidence supported the Board’s conclusion that, “without credible testimony, [the petitioner] failed to establish eligibility for asylum or withholding of removal”); Manes v. Sessions, 875 F.3d 1261, 1265 (9th Cir. 2017) (per curiam) (“Because the Board’s adverse credibility determination is supported 2 by substantial evidence, [the petitioner] cannot satisfy his burden of proving he is eligible for asylum and withholding of removal.”). 2.
discussed Cited as authority (rule) He v. Bondi
9th Cir. · 2025 · confidence medium
The BIA and IJ are permitted to afford substantial weight to an “inconsistency [that] bears directly on [the petitioner’s] claim of persecution.” Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017).
discussed Cited as authority (rule) Ying v. McHenry
9th Cir. · 2025 · confidence medium
See id. at 1048 (adverse credibility finding reasonable under the totality of the circumstances); Mukulumbutu v. Barr, 977 F.3d 924, 926 (9th Cir. 2020) (sufficient indicia of reliability permitted consideration of interview where conducted under oath, with contemporaneous notes containing questions asked, and transcribed with aid of interpreter); Manes v. Sessions, 875 F.3d 1261, 1263-64 (9th Cir. 2017) (agency’s demeanor finding supported where IJ provided “specific, first-hand observations,” and inconsistency between applicant’s testimony and documentary evidence undermined credibil…
discussed Cited as authority (rule) He v. Garland
9th Cir. · 2024 · confidence medium
We uphold an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Singh v. Garland
9th Cir. · 2024 · confidence medium
“Under the REAL ID Act, . . . the IJ is authorized to base an adverse credibility determination on the totality of the circumstances and all relevant factors.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (internal quotation marks omitted).
discussed Cited as authority (rule) Singh v. Garland
9th Cir. · 2024 · confidence medium
“Under the REAL ID Act, . . . the IJ is authorized to base an adverse credibility determination on the totality of the circumstances and all relevant factors.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (internal quotation marks omitted).
discussed Cited as authority (rule) Piao v. Garland
9th Cir. · 2024 · confidence medium
We must uphold an adverse credibility determination “unless any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Fa v. Garland
9th Cir. · 2024 · confidence medium
Under the REAL ID Act, an IJ may “base an adverse credibility determination on any relevant factor that . . . can reasonably be said to have a ‘bearing on a petitioner’s veracity,’” Ren v. Holder, 648 F.3d 1079, 1084 (9th Cir. 2011) (quoting Shrestha, 590 F.3d at 1044 ), including any “inconsistencies between the petitioner’s statements and other evidence of record,” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Wang v. Garland (2×) also: Cited "see, e.g."
9th Cir. · 2024 · confidence medium
We uphold an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Chen v. Garland
9th Cir. · 2023 · confidence medium
We uphold an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Su v. Garland
9th Cir. · 2023 · confidence medium
See id. at 1048 (adverse credibility finding reasonable under the totality of the circumstances); Manes v. Sessions, 875 F.3d 1261, 1263-64 (9th Cir. 2017) (agency’s demeanor finding was supported where IJ provided “specific, first-hand observations”).
cited Cited as authority (rule) Toloza Ibarra v. Garland
9th Cir. · 2023 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1265 (9th Cir. 2017).
discussed Cited as authority (rule) Wu v. Garland
9th Cir. · 2023 · confidence medium
The agency “properly considered the totality of the circumstances and supported [the] adverse credibility determination with specific and cogent reasons.” Manes v. Session, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Chabaja v. Garland (2×) also: Cited "see, e.g."
9th Cir. · 2023 · confidence medium
These “specific, first-hand observations” are “precisely the kind of credibility cues that are the special province of the factfinder.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam); see also id. (upholding the IJ’s demeanor finding where the IJ observed that petitioner was “visibly nervous” and spoke “notably faster” in response to questioning).
discussed Cited as authority (rule) Singh v. Garland
9th Cir. · 2023 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (the BIA may give “substantial weight” to inconsistencies that bear directly on the applicant’s claims).
discussed Cited as authority (rule) Aracely Colindres-Palacios v. Merrick Garland
9th Cir. · 2023 · confidence medium
See id. at 1048 (adverse credibility finding reasonable under the totality of the circumstances); Zamanov v. Holder, 649 F.3d 969, 973-74 (9th Cir. 2011) (petitioner’s omissions supported adverse credibility determination where they did not constitute “a mere lack of detail” but “went to the core of his alleged fear”); Manes v. Sessions, 875 F.3d 1261, 1263-64 (9th Cir. 2017) (agency’s demeanor finding was supported where IJ provided “specific, first-hand observations”).
discussed Cited as authority (rule) Aifeng Jin v. Merrick Garland
9th Cir. · 2023 · confidence medium
See id. at 1048 (adverse credibility finding reasonable under the totality of the circumstances); see also Barseghyan v. Garland, 39 F.4th 1138, 1146 (9th Cir. 2022) (lack of documentation was one factor supporting adverse credibility determination); Manes v. Sessions, 875 F.3d 1261, 1263-64 (9th Cir. 2017) (agency’s demeanor finding was supported where IJ provided “specific, first-hand observations,” and an inconsistency between applicant’s testimony and documentary evidence undermined credibility); Zamanov v. Holder, 649 F.3d 969, 973-74 (9th Cir. 2011) (petitioner’s omissions supp…
discussed Cited as authority (rule) Baozhen Gong v. Merrick Garland
9th Cir. · 2022 · confidence medium
See id. at 1048 (adverse credibility determination reasonable under the “totality of the circumstances”); see also Rodriguez-Ramirez v. Garland, 11 F.4th 1091 , 1093 (9th Cir. 2021) (agency can afford substantial weight to inconsistencies that bear directly on petitioner’s claim of persecution); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (agency’s demeanor finding supported where IJ provided “specific, first-hand observations”).
cited Cited as authority (rule) Avetik Grigoryan v. Merrick Garland
9th Cir. · 2022 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
cited Cited as authority (rule) Lijun Zhao v. Merrick Garland
9th Cir. · 2022 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017).
discussed Cited as authority (rule) Gilber Garcia-Ventura v. Merrick Garland
9th Cir. · 2022 · confidence medium
We must uphold an adverse credibility determination “unless any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Sandra Javiel Torres v. Merrick Garland
9th Cir. · 2022 · confidence medium
We will not disturb an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Jianhua Shen v. Merrick Garland
9th Cir. · 2022 · confidence medium
We will not disturb an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Zhipeng Qu v. Merrick Garland
9th Cir. · 2022 · confidence medium
See Shrestha, 590 F.3d at 1048 (adverse credibility determination reasonable under “the totality of circumstances”); see also Li v. Garland, 13 F.4th 954, 961 (9th Cir. 2021) (applicant’s false information on visa application supported adverse credibility determination); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (agency’s demeanor finding was supported where IJ provided “specific, first-hand observations”).
cited Cited as authority (rule) Shenglan Sun v. Merrick Garland
9th Cir. · 2022 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (citation omitted).
cited Cited as authority (rule) Ernest Tekang v. Merrick Garland
9th Cir. · 2022 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (quoting Shrestha v. Holder, 590 F.3d 1034, 1041 (9th Cir. 2010)).
discussed Cited as authority (rule) Francisco Nunez-Gonzalez v. Merrick Garland
9th Cir. · 2022 · confidence medium
Although Petitioner’s omissions alone are sufficient to uphold the agency’s conclusion, see Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam), the IJ’s finding is further supported by the noted inconsistencies between Petitioner’s testimony regarding Jose’s cartel connections and the testimony and written declaration of Petitioner’s sister, in which she denied that Jose was, or ever had been, part of a cartel.
discussed Cited as authority (rule) Xiuhua Chi v. Merrick Garland
9th Cir. · 2022 · confidence medium
We give deference to agency credibility determinations, because “IJs are in the best position to assess demeanor and other credibility cues that we cannot readily [assess] on review.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (post-REAL ID Act) (citing Shrestha v. Holder, 590 F.3d 1034, 1041 (9th Cir. 2010)).
discussed Cited as authority (rule) Peter Udo v. Merrick Garland
9th Cir. · 2022 · confidence medium
In Manes v. Sessions, unlike here, there was no indication that the BIA had failed to consider all the evidence, not in the least because the objective evidence Manes presented—country conditions reports—had little probative value for his particular CAT claim. 875 F.3d 1261, 1265 (9th Cir. 2017).
discussed Cited as authority (rule) Gabriel Saavedra Ortiz v. Merrick Garland
9th Cir. · 2022 · confidence medium
Thus, the BIA identified “specific and cogent reasons” to support its adverse credibility determination, Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017), and Petitioner has failed to show that the record compels a contrary result.
discussed Cited as authority (rule) Francisco Batres-Roca v. Merrick Garland
9th Cir. · 2022 · confidence medium
In contrast to his testimony that guerrillas murdered four of his family members in 1981, his documentary evidence—namely, a news article—declared that a “crime group” committed a “crime” in which “strangers killed four members of one family[.]” We have ruled that substantial evidence supported an adverse credibility finding where inconsistencies between a noncitizen’s testimony and his 4 documentary evidence “b[ore] directly on [his] claim of persecution[.]” Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (citation omitted).
cited Cited as authority (rule) Meimei Ni v. Merrick Garland
9th Cir. · 2022 · confidence medium
Martinez-Serrano v. INS, 94 F.3d 1256, 1259 (9th Cir. 1996). 2 v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Ya Xiao v. Merrick Garland
9th Cir. · 2022 · confidence medium
We uphold an adverse credibility determination unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252 (b)(4)(B); Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam). “[T]here is no presumption that an applicant for relief is credible, and the IJ is authorized to base an adverse credibility determination on ‘the totality of the circumstances’ and ‘all 1 Because Petitioner did not raise any argument before the BIA or this court about the denial of her claim for Convention Against Torture relief, it is waived.
cited Cited as authority (rule) Wei Zheng v. Merrick Garland
9th Cir. · 2022 · confidence medium
Martinez-Serrano v. INS, 94 F.3d 1256, 1259 (9th Cir. 1996). 2 v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Hong Chen v. Merrick Garland
9th Cir. · 2022 · confidence medium
“Under the REAL ID Act, which applies here, there is no presumption that an applicant for relief is credible, and the IJ is authorized to base an adverse credibility determination on the totality of the circumstances and all relevant factors.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (citations and internal quotation marks omitted).
cited Cited as authority (rule) Junshan Fang v. Merrick Garland
9th Cir. · 2022 · confidence medium
But we rejected this argument in Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Qing Zhang v. Merrick Garland
9th Cir. · 2022 · confidence medium
Contrary to Zhang’s assertions, the IJ considered Zhang’s and Harold’s explanations for some of the underlying inconsistencies, see Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam), but permissibly chose to reject the explanations in making the credibility determinations, see Zamanov v. Holder, 649 F.3d 969, 974 (9th Cir. 2011).
discussed Cited as authority (rule) Yogney Pereira Camacho v. Merrick Garland
9th Cir. · 2022 · confidence medium
See Shrestha, 590 F.3d at 1048 (adverse credibility determination reasonable under the “totality of the circumstances”); see also Lalayan v. Garland, 4 F.4th 822 , 836 (9th Cir. 2021) (testimony that is implausible may support an adverse credibility finding); Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (agency properly relied on an inconsistency between the applicant’s testimony and a letter he submitted in support of his claim).
cited Cited as authority (rule) Leonardo Perez-Garcia v. Merrick Garland
9th Cir. · 2021 · signal: cf. · confidence medium
Cf. Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam).
cited Cited as authority (rule) Ming Lin v. Merrick Garland
9th Cir. · 2021 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam).
discussed Cited as authority (rule) Shuhui Cao v. Merrick Garland
9th Cir. · 2021 · confidence medium
We give deference to agency credibility determinations, because “IJs are in the best position to assess demeanor and other credibility cues that we cannot readily [assess] on review.” Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (post-REAL ID Act) (citing Shrestha v. Holder, 590 F.3d 1034, 1041 (9th Cir. 2010)).
cited Cited as authority (rule) Yudai Ma v. Merrick Garland
9th Cir. · 2021 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam). 2.
discussed Cited as authority (rule) Wanhe Deng v. Merrick Garland
9th Cir. · 2021 · confidence medium
The agency was required to consider Petitioner’s explanations, see Manes v. Sessions, 875 F.3d 1261, 1263 (9th Cir. 2017) (per curiam) (holding that a "petitioner’s explanation for the inconsistency, if any, should be considered in weighing credibility" (internal quotation marks omitted)), and it did.
cited Cited as authority (rule) Juliana Guzman Hernandez v. Merrick Garland
9th Cir. · 2021 · confidence medium
See 8 U.S.C. § 1158 (b)(1)(B)(ii); Manes v. Sessions, 875 F.3d 1261, 1265 (9th Cir. 2017).
cited Cited as authority (rule) Zuliema Guerrero-Esperanza v. Robert Wilkinson
9th Cir. · 2021 · confidence medium
Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (per curiam) (citation omitted).
discussed Cited as authority (rule) Harjinder Singh v. Robert Wilkinson
9th Cir. · 2021 · confidence medium
Additionally, the IJ’s demeanor finding adequately referred to the non-credible aspects of Singh’s demeanor: “[H]e testified confidently and clearly on direct examination but became nonresponsive, evasive, and self-contradictory when questioned about inconsistencies.” See Manes v. Sessions, 875 F.3d 1261, 1264 (9th Cir. 2017) (“[A]n IJ can meet the IJ’s obligation to provide specific examples of the petitioner’s demeanor by making explicit reference to particular unrecorded aspects of demeanor” (internal quotation marks omitted)).
Retrieving the full opinion text from the archive…
Malak MANES, Petitioner,
v.
Jefferson B. SESSIONS III, Attorney General, Respondent
14-73313.
Court of Appeals for the Ninth Circuit.
Nov 27, 2017.
875 F.3d 1261
Morgan Russell (argued), Anne E. Peterson, and Robert Jobe, Law Office of Robert B. Jobe, San Francisco, California, for Petitioner., Andrew B. Insenga (argued), Trial Attorney; Douglas E. Ginsburg, Assistant Director; Office of Immigration Litigation, Civil Division, United States Department of Justice, Washington, D.C.; for Respondent.
Wallace, Tashima, Watford.
Cited by 123 opinions  |  Published  |  Agency

OPINION

PER CURIAM:

Malak Manes, a native and citizen of India, petitions for review of the Board of Immigration Appeals’ (Board) order affirming an immigration judge’s (IJ) denial of his applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). Manes argues that he was persecuted in India because of his support for the India National Order Lok Dal (INLD), one of the country’s opposition political parties. We have jurisdiction under 8 U.S.C. § 1252(a)(1), and we deny Manes’ petition.

The Board affirmed the. IJ’s denial of relief on the basis of the IJ’s adverse credibility determination. “Because credibility determinations are findings of fact by the IJ, they ‘are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.’” Rizk v. Holder, 629 F.3d 1083, 1087 (9th Cir. 2011) (quoting 8 U.S.C. § 1252(b)(4)(B)). We afford a “healthy measure of deference to agency credibility determinations,” mindful that “Us are in the best position to assess demeanor and other credibility cues that we cannot readily access [sic] on review.” Shrestha v. Holder, 590 F.3d 1034, 1041 (9th Cir. 2010).

Under the REAL ID Act, which applies here, “there is no presumption that an applicant for relief is credible, and the IJ is authorized to base an adverse credibility determination on ‘the totality of the circumstances’ and ‘all relevant factors.’” Ling Huang v. Holder, 744 F.3d 1149, 1152-53 (9th Cir. 2014) (quoting 8 U.S.C. § 1158(b)(l)(B)(iii)). Such factors include the alien’s “demeanor, candor, or responsiveness.” 8 U.S.C. § 1158(b)(l)(B)(iii). Demeanor findings “should specifically point out the noncredible aspects of the petitioner’s demeanor.” Shrestha, 590 F.3d at 1042. The IJ may also consider inconsistencies between the petitioner’s statements and other evidence of record. 8 U.S.C. § 1158(b)(l)(B)(iii). “When an inconsistency is cited as a factor supporting an adverse credibility determination, that inconsistency should not be a mere trivial error such as a misspelling, and the petitioner’s explanation for the inconsistency, if any, should be considered in weighing credibility.” Shrestha, 590 F.3d at 1044 (citations omitted). Regardless of the factors relied upon by the IJ, the IJ must provide “specific and cogent .reasons” to .support an adverse credibility determination. Id. at 1042.

Here, the IJ properly considered the totality of thé circumstances and supported her adverse credibility determination with specific and cogent reasons. Manes fails to show that the evidence' of record compels a contrary result.

We reject Manes’ argument that the IJ’s demeanor findings were insufficiently precise. The IJ stated that Manes was “visibly nervous” when confronted with évidence that contradicted his claim and “would move his hands to the extent that his bracelets would make a noise.” The IJ also found that Manes’ speech was “notably faster” and “had an almost desperate tone” when Manes was responding to confrontations or difficult questions. Moreover, the IJ explained that Manes’ anxious demeanor on cross-examination was “in sharp contrast” to his “calm and measured” demeanor on direct, characterizing the contrast as “remarkable.” These are specific, first-hand observations—precisely the kind of credibility cues that are the special province of the factfinder. Given the IJ’s unique ability to assess firsthand a petitioner’s demeanor, “it would be extraordinary for a reviewing court to substitute its second-hand impression of the petitioner’s 'demeanor .... for that of the IJ.” Jibril v. Gonzales, 428 F.3d 1129,1137 (9th Cir. 2005).

Manes contends that the IJ should have commented on Manes’ demeanor and credibility at the time of occurrence, so that the transcript would reflect the exact moments during the hearing when the IJ was assessing Manes’ demeanor. It' is true that in some of our cases a hearing transcript has provided evidence supporting an IJ’s demeanor findings. See, e.g., Huang, 744 F.3d at 1154-56. But our case law does not require the IJ to conduct a running commentary on the alien’s credibility. See Paredes-Urrestarazu v. U.S. INS, 36 F.3d 801, 818 (9th Cir. 1994) (“We certainly cannot expect that the factual basis for eye-witness observations always will find support in the hearing transcript.”). In fact, we have indicated that an IJ can meet the IJ’s obligation to provide “specific examples” of the petitioner’s demeanor by making “explicit reference to particular unrecorded aspects of demeanor,” Kin v. Holder, 595 F.3d 1050, 1056 (9th Cir. 2010), including “the expression of [the petitioner’s] countenance, how he sits or stands, whether he is inordinately nervous, his coloration during critical examination, the modulation or pace of his speech and other non-verbal communication.” Huang, 744 F.3d at 1153 (quoting Shrestha, 590 F.3d at 1042). These are precisely the aspects of Manes’ demeanor the IJ referenced here. Thus, the IJ’s demeanor findings were sufficiently specific and supported by substantial evidence.

We also reject Manes’ argument that the Board did not have substantial evidence to conclude that inconsistencies between his testimony and the documentary evidence of record undermined his credibility. Manes testified he received stitches on his left hand after a March 2009 attack by a knife-wielding assailant. However, Manes submitted a letter purporting to be from the doctor in India who treated him after the March 2009 attack that states only that Manes suffered injuries to his “left arm and left shoulder” arid received stitches on his left arm. There is no mention of “hand”' in the doctor’s letter. This inconsistency bears directly on Manes’ claim of persecution, thus permitting the Board to afford it substantial weight. Shrestha, 590 F.3d at 1046-47 (“Although inconsistencies, no longer need to go to the heart of the petitioner’s claim, when an inconsistency is at the heart of the claim it doubtless is of great weight.”).

Manes argues this inconsistency cannot support an adverse credibility determination because the doctor’s letter is not reliable. We disagree. Manes himself submitted the document to support his claim. The IJ considered the letter along with the other evidence of record and identified an inconsistency between Manes’ testimony and the letter. This is precisely the procedure the IJ is expected to follow when considering the totality of the circumstances. See 8 U.S.C. § 1158(b)(l)(B)(iii). Manes cannot dispel an inconsistency between his testimony and the evidence of record by attempting to discredit the reliability of his own evidence after the fact. Here, the inconsistency between Manes’ testimony and the doctor’s letter concerning the nature of Manes’ only documented physical injury is a specific and cogent reason supporting the IJ’s adverse credibility determination.

Substantial evidence also supports the Board and the IJ’s determination that issues with Manes’ other documentary evidence undermined his credibility. For example, a letter purportedly from an INLD district party chief contained a handwritten edit to the organization’s email address. In addition, the INLD voter roster submitted by Manes listed him as a 25-year-old female, rather than his actual age and gender, a 22-year-old male. Of course, “an utterly trivial inconsistency, such as a typographical error, will not by itself form a sufficient basis for an adverse credibility determination.” Shrestha, 590 F.3d at 1043. But the INLD letter and voter roster speak directly to Manes’ claimed basis for persecution—that is, his support of, and membership in, the INLD. Given the relevance of these documents to Manes’ claim, even minor issues with the documents may be given substantial weight by the Board. Id. at 1046-47.

In sum, the Board’s conclusion that the IJ properly denied Manes’ asylum and withholding of removal claims on adverse credibility grounds is supported by substantial evidence. The IJ’s demeanor findings were sufficiently specific, and the Board and IJ provided specific and cogent reasons for why inaccuracies in Manes’ documentary evidence, and inconsistencies between Manes’ statements and other evidence of record, undermined his credibility. Because the Board’s adverse credibility determination is supported by substantial evidence, Manes cannot satisfy his burden of proving he is eligible for asylum and withholding of removal.

Finally, we reject Manes’ argument that the Board’s denial of his application for protection under the CAT must be reversed because the Board did not fully understand the country conditions evidence of record. The Board specifically determined that “[i]n light of the adverse credibility finding, the objective evidence of record alone is insufficient” to demonstrate Manes’ entitlement to CAT protection. (Emphasis added). The Board then cited the portion of our decision in Shrestha discussing the relevance of country conditions reports to a CAT claim. This is sufficient evidence that the Board considered the reports. The reports themselves discuss episodes of ethnic and communal violence in various regions of India, police abuses of power, and incidents where government security forces allegedly tortured insurgents and alleged terrorists. This evidence falls far short of compelling the conclusion that Manes is more likely than not to be tortured if he returns to India. See Dhital v. Mukasey, 532 F.3d 1044, 1051-52 (9th Cir. 2008) (explaining that State Department reports alone will compel the conclusion that a petitioner is more likely than not to be tortured only where the reports demonstrate the petitioner would face a “particularized threat” of torture if returned). Therefore, the Board’s determination that Manes is not entitled to protection under the CAT is supported by substantial evidence.

For the foregoing reasons, Manes’ petition for review of the Board’s decision is DENIED.