Leonardo Campos-sanchez, Petitioner, v. Immigr. & Naturalization Serv., Respondent, 164 F.3d 448 (9th Cir. 1999). · Go Syfert
Leonardo Campos-sanchez, Petitioner, v. Immigr. & Naturalization Serv., Respondent, 164 F.3d 448 (9th Cir. 1999). Cases Citing This Book View Copy Cite
329 citation events (257 in the last 25 years) across 10 distinct courts.
Strongest positive: Makane Rwaril v. Eric Holder, Jr. (ca9, 2010-08-23)
Treatment trajectory · 1999 → 2026 · click a year to view as-of
1999 2012 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Makane Rwaril v. Eric Holder, Jr. (2×) also: Cited "see"
9th Cir. · 2010 · signal: see · quote attribution · 1 verbatim quote · confidence high
the bia must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.
discussed Cited as authority (verbatim quote) Hernandez v. Mukasey
9th Cir. · 2008 · signal: see · quote attribution · 1 verbatim quote · confidence high
the fifth amendment guarantees due process in deportation proceedings.
discussed Cited as authority (verbatim quote) Hernandez-Gil v. Gonzales
9th Cir. · 2007 · signal: see · quote attribution · 1 verbatim quote · confidence high
the fifth amendment guar- antees due process in deportation proceedings.
examined Cited as authority (verbatim quote) Raj Kumar v. Gonzales (4×) also: Cited "see"
9th Cir. · 2006 · signal: see · quote attribution · 1 verbatim quote · confidence high
the bia must provide a petitioner with a reasonable opportunity to offer an explana- tion of any perceived inconsistencies that form the basis of a denial of asylum.
discussed Cited as authority (verbatim quote) Marcos v. Gonzales
9th Cir. · 2005 · quote attribution · 1 verbatim quote · confidence high
the bia must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum
discussed Cited as authority (verbatim quote) United States v. Higareda-Ramirez (2×) also: Cited as authority (rule)
D. Haw. · 2000 · quote attribution · 1 verbatim quote · confidence high
under this circuit's case law, an alien must receive a 'full and fair hearing,' in order to meet the requirements of due process
cited Cited as authority (rule) Francisco Hernandez v. Pamela Bondi
9th Cir. · 2026 · confidence medium
Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Tan Hoang Bui v. Bruce Scott, et al.
W.D. Wash. · 2025 · confidence medium
“The Fifth Amendment 7 guarantees due process in deportation proceedings.” Torres-Aguilar v. I.N.S., 246 F.3d 1267 , 8 1270 (9th Cir. 2001) (citing Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir. 1999), 9 superseded by statute on other grounds in Arizmendi-Medina v. Garland, 69 F.4th 1043 , 1053 10 (9th Cir. 2023)).
discussed Cited as authority (rule) Jorge Rivera Larios v. Sergio Albarran, et al.
N.D. Cal. · 2025 · confidence medium
“The 5 Fifth Amendment guarantees due process in deportation proceedings.” Torres-Aguilar v. I.N.S., 6 246 F.3d 1267, 1270 (9th Cir. 2001) (citing Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir. 7 1999), superseded by statute on other grounds as stated in Arizmendi-Medina v. Garland, 69 F.4th 8 1043, 1053 (9th Cir. 2023)).
discussed Cited as authority (rule) United States v. Leopoldo Rivera-Valdes
9th Cir. · 2025 · confidence medium
INS, 311 F.3d 1206, 1210 (9th Cir. 2002) (“Aliens facing deportation are entitled to due process under the Fifth Amendment... encompassing a full and fair hearing and notice of that hearing.”); Barraza Rivera v. INS, 913 F.2d 1443, 1447 (9th Cir. 1990) (“The Fifth Amendment guarantees due process in deportation proceedings.”); Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999) (accord).
discussed Cited as authority (rule) Rupailla Castro v. Bondi
9th Cir. · 2025 · confidence medium
On this record, we do not conclude that “the IJ’s ‘conduct potentially affected the outcome of the proceedings,’” Colmenar v. I.N.S., 210 F.3d 967, 972 (9th Cir. 2000) (quoting Campos–Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999)), or “prevented the introduction of significant testimony,” Oshodi v. Holder, 729 F.3d 883, 890 (9th Cir. 2013) (quoting Lopez–Umanzor v. Gonzales, 405 F.3d 1049, 1056 (9th Cir. 2005)), so as to constitute a due process violation. 3 24-1271 Substantial evidence supports the IJ’s conclusion and BIA’s affirmance that Rupailla Castro is ineligib…
discussed Cited as authority (rule) Nguyen v. Scott
W.D. Wash. · 2025 · confidence medium
“The Fifth Amendment guarantees due process in deportation 12 proceedings.” Torres-Aguilar v. I.N.S., 246 F.3d 1267, 1270 (9th Cir. 2001) (citing Campos- 13 Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir. 1999), superseded by statute on other grounds in 14 Arizmendi-Medina v. Garland, 69 F.4th 1043 , 1053 (9th Cir. 2023)). 15 Second, Petitioner has also raised serious questions going to the merits of his claim that 16 the Government has failed to carry out a non-discretionary duty under the Administrative 17 Procedure Act and relevant regulations.
discussed Cited as authority (rule) Ortega v. Kaiser
N.D. Cal. · 2025 · confidence medium
“The 20 Fifth Amendment guarantees due process in deportation proceedings.” Torres-Aguilar v. I.N.S., 21 246 F.3d 1267, 1270 (9th Cir. 2001) (citing Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir. 22 1999), superseded by statute on other grounds as stated in Arizmendi-Medina v. Garland, 69 F.4th 23 1043, 1053 (9th Cir. 2023)).
discussed Cited as authority (rule) Carlos Contreras Rivas v. Merrick Garland
9th Cir. · 2024 · confidence medium
Contreras claims that the agency did not give him an opportunity to explain certain inconsistencies in his testimony and failed to give specific and cogent reasons for rejecting the explanations he did provide.1 See Jie Cui v. Holder, 712 F.3d 1332, 1336 (9th Cir. 2013); Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) United States v. Leopoldo Rivera-Valdes
9th Cir. · 2024 · confidence medium
See also Dobrota, 311 F.3d at 1210 (“Aliens facing deportation are entitled to due process under the Fifth Amendment to the United States Constitution, encompassing a full and fair hearing and notice of that hearing.”); Barraza Rivera v. INS, 913 F.2d 1443, 1447 (9th Cir. 1990) (“The Fifth Amendment guarantees due process in deportation proceedings.”); Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999) (accord). “‘The fundamental requisite of due process of law is the opportunity to be heard.’” Mullane, 339 U.S. at 314 (quoting Grannis v. Ordean, 234 U.S. 385, 394 (1914))…
cited Cited as authority (rule) Cruz-Alvarez v. Garland
9th Cir. · 2023 · confidence medium
Vargas- Hernandez v. Gonzales, 497 F.3d 919, 926 (9th Cir. 2007) (quoting Campos– Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999)).
discussed Cited as authority (rule) Garcia Martinez v. Garland
9th Cir. · 2023 · confidence medium
See Munyuh v. Garland, 11 F.4th 750 , 758 (9th Cir. 2021); Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999) superseded by statute on other grounds as stated in Xia Xia Lin v. Mukasey, 534 F.3d 162, 165 (2d Cir. 2008) (per curiam); see also Ordonez v. INS, 345 F.3d 777, 786 (9th Cir. 2003) (recognizing that the BIA may in some circumstances make a de facto adverse credibility finding).
discussed Cited as authority (rule) Freddy Lopez-Aguilar v. Merrick Garland
9th Cir. · 2022 · confidence medium
The BIA did not abuse its discretion in declining to reopen Lopez-Aguilar’s case based on alleged due process violations in his deportation proceedings.1 A non- citizen “is entitled to a ‘full and fair hearing’ that meets the requirements of due process.” Vargas-Hernandez v. Gonzales, 497 F.3d 919, 926 (9th Cir. 2007) (quoting Campos–Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999)). “[I]f [a non- citizen] shows ‘indicia of incompetency,’ the [immigration judge (“IJ”)] has an independent duty to determine whether the [non-citizen] is competent.” Mejia v. Sessions, 868 …
cited Cited as authority (rule) Heyi Shao v. Merrick Garland
9th Cir. · 2021 · confidence medium
Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Cecilia Aguilar Fermin v. William Barr
9th Cir. · 2020 · confidence medium
BARR 13 required, Aguilar was given an opportunity to explain the inconsistencies and implausibilities in her testimony, see Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999), superseded by statute on other grounds as stated in Xiu Xia Lin v. Mukasey, 534 F.3d 162, 165 (2d Cir. 2008) (per curiam), but the IJ found her explanations, including that “she was nervous” and “she had forgotten” certain facts, were unconvincing.
discussed Cited as authority (rule) Ying Li v. William Barr
9th Cir. · 2020 · confidence medium
Li is correct that any purported discrepancy was too trivial to support an adverse credibility determination, see Shrestha, 590 F.3d at 1043–44, and that the agency failed to provide Li with a “reasonable opportunity” to explain the perceived inconsistency regarding the provenance of the household register, see Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
cited Cited as authority (rule) Fany Fajardo-Paz v. William Barr
9th Cir. · 2019 · confidence medium
“The Fifth Amendment guarantees due process in deportation proceedings.” Campo-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
cited Cited as authority (rule) Juan Gadidas Gonzalez v. Matthew Whitaker
9th Cir. · 2018 · confidence medium
See Joseph v. Holder, 600 F.3d 1235, 1244-1245 (9th Cir. 2010); Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Saiful Islam v. Jefferson Sessions
9th Cir. · 2018 · confidence medium
See Colmenar v. INS, 210 F.3d 967, 971 (9th Cir. 2000) (remanding asylum case for a new hearing where IJ did not act as neutral fact finder but as partisan adjudicator); Castro-Cortez v. INS, 239 F.3d 1037 , 1049 (9th Cir. 2001) (“A neutral judge is one of the most basic due process protections.”) “If the prejudice to the alien is sufficiently great, denial of the right to a full and fair hearing may violate the constitutional guarantee of due process.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Jesus Padilla-Martinez v. Eric Holder, Jr.
9th Cir. · 2014 · confidence medium
See Cinapian v. Holder, 567 F.3d 1067, 1074-75 (9th Cir.2009); Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir.1999), superseded by statute on other grounds as stated in Xiu Xia Lin v. Mukasey, 534 F.3d 162, 165 (2d Cir.2008) (per curiam).
discussed Cited as authority (rule) Hao Zhou v. Eric Holder, Jr.
9th Cir. · 2013 · confidence medium
See Singh v. Gonzales, 439 F.3d 1100, 1106 (9th Cir.2006); Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999). * ❖ We GRANT Zhou’s petition for review of the BIA’s dismissal of his claims for asylum, withholding of removal and protection under the Convention Against Torture, and we REMAND for further proceedings to determine whether, accepting his testimony as credible, he is eligible for relief. * This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.
cited Cited as authority (rule) Ren v. Holder
9th Cir. · 2011 · confidence medium
Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Huibo Wang v. Holder
9th Cir. · 2011 · confidence medium
Due process requires that a petitioner be given a “full and fair hearing.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999), superseded by statute as recognized in Xiu Xia Lin v. Mukasey, 534 F.3d 162, 165 (2d Cir.2008) (describing effects of the REAL ID Act).
discussed Cited as authority (rule) Zetino v. Holder (2×) also: Cited "see"
9th Cir. · 2010 · confidence medium
“The Fifth Amendment guarantees due process in deportation proceedings.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Mary Kariuki v. Eric H. Holder Jr. (2×)
9th Cir. · 2010 · confidence medium
Quan v. Gonzales, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Sukhwinder Singh v. Eric Holder, Jr.
9th Cir. · 2010 · confidence medium
Before making an adverse credibility determination in a pre-REAL ID Act case such as this one, the IJ must give the petitioner “a reasonable opportunity to offer an explanation of any perceived inconsistencies.” Campos -Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999), superseded by statute 1 as stated in Xiu Xia Lin v. Mukasey, 534 F.3d 162, 165 (2nd Cir.2008) (per curiam).
discussed Cited as authority (rule) Cruz Rendon v. Holder
9th Cir. · 2010 · confidence medium
ANALYSIS “An alien is entitled to a ‘full and fair hearing’ that meets the requirements of due process.” Vargas-Hernandez v. Gonzales, 497 F.3d 919, 926 (9th Cir.2007) (quoting Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999)).
cited Cited as authority (rule) Singh v. Holder
9th Cir. · 2010 · confidence medium
Campos-Sanchez v. I.N.S., 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Kyi Kyi Swe v. Holder
9th Cir. · 2010 · confidence medium
The IJ erred by failing to take into account the context of individual statements, failing to confront Swe concerning some alleged inconsistencies, see Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999), failing to respond to explanations of alleged inconsistencies, see Soto-Olarte v. Holder, 555 F.3d 1089, 1091 (9th Cir.2009), and finding inconsistencies between Swe’s testimony and his own mere speculation and conjecture, see Ge v. Ashcroft, 367 F.3d 1121, 1124 (9th Cir.2004).
discussed Cited as authority (rule) Tupikovskaya v. Holder
9th Cir. · 2010 · confidence medium
The IJ failed to provide Tupiµovsµaya with a reasonable opportunity to address inconsistencies A petitioner must be provided with a 'reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.' Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
discussed Cited as authority (rule) Tupikovskaya v. Holder
9th Cir. · 2010 · confidence medium
The IJ failed to provide Tupikov-skaya with a reasonable opportunity to address inconsistencies A petitioner must be provided with a “reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Zetino v. Holder (2×) also: Cited "see"
9th Cir. · 2010 · confidence medium
“The Fifth Amendment guaran- tees due process in deportation proceedings.” Campos- Sanchez v. INS, 164 F.3d 448, 450 (9th Cir. 1999).
examined Cited as authority (rule) Zetino v. Holder (3×) also: Cited "see"
9th Cir. · 2010 · confidence medium
“The Fifth Amendment guarantees due process in deportation proceedings.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Tupikovskaya v. Holder
9th Cir. · 2010 · confidence medium
The IJ failed to provide Tupikov-skaya with a reasonable opportunity to address inconsistencies A petitioner must be provided with a “reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Cruz Rendon v. Holder
9th Cir. · 2009 · confidence medium
ANALYSIS “An alien is entitled to a ‘full and fair hearing’ that meets the requirements of due process.” Vargas-Hernandez v. Gonzales, 497 F.3d 919, 926 (9th Cir.2007) (quoting Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999)).
discussed Cited as authority (rule) Atta v. Holder
9th Cir. · 2009 · confidence medium
Although an IJ is permitted “to exercise common sense in rejecting a petitioner’s testimony,” Jibril v. Gonzales, 423 F.3d 1129, 1135 (9th Cir. 2005), the IJ in this case impermissibly failed to ask about or afford Atta an opportunity to explain the conduct the IJ found questionable. “[T]he BIA must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999); see also Quan v. Gonzales, 428 F.3d 883, 886 (9th Cir.2005) (A petitioner’s �…
discussed Cited as authority (rule) Atta v. Holder
9th Cir. · 2009 · confidence medium
Although an IJ is permitted “to exercise common sense in rejecting a petitioner’s testimony,” Jibril v. Gonzales, 423 F.3d 1129, 1135 (9th Cir. 2005), the IJ in this case impermissibly failed to ask about or afford Atta an opportunity to explain the conduct the IJ found questionable. “[T]he BIA must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999); see also Quan v. Gonzales, 428 F.3d 883, 886 (9th Cir.2005) (A petitioner’s �…
cited Cited as authority (rule) Zamudio-Pena v. Holder
9th Cir. · 2009 · confidence medium
“The Fifth Amendment guarantees due process in deportation proceedings.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
cited Cited as authority (rule) Zamudio-Pena v. Holder
9th Cir. · 2009 · confidence medium
“The Fifth Amendment guarantees due process in deportation proceedings.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Soto v. Holder
9th Cir. · 2009 · confidence medium
We agree with the BIA that, assuming Soto could establish ineffective assistance of counsel, he has nonetheless failed to demonstrate prejudice; he cannot show that any ineffectiveness “ ‘potentially affected the outcome of the proceedings.’ ” Colmenar v. INS, 210 F.3d 967, 972 (9th Cir.2000) (quoting Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999)).
discussed Cited as authority (rule) Soto v. Holder
9th Cir. · 2009 · confidence medium
We agree with the BIA that, assuming Soto could establish ineffective assistance of counsel, he has nonetheless failed to demonstrate prejudice; he cannot show that any ineffectiveness “ ‘potentially affected the outcome of the proceedings.’ ” Colmenar v. INS, 210 F.3d 967, 972 (9th Cir.2000) (quoting Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999)).
discussed Cited as authority (rule) Mayala v. Holder
9th Cir. · 2009 · confidence medium
First, “the BIA must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
discussed Cited as authority (rule) Mayala v. Holder
9th Cir. · 2009 · confidence medium
First, “the BIA must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.” Campos-Sanchez v. INS, 164 F.3d 448, 450 (9th Cir.1999).
examined Cited as authority (rule) Soto-Olarte v. Holder (3×)
9th Cir. · 2009 · confidence medium
See, e.g., Kaur, 379 F.3d at 884 (“An adverse credibility finding is improper when an IJ fails to address a petitioner’s explanation for a discrepancy or inconsistency.”); Guo v. Ashcroft, 361 F.3d 1194, 1201 (9th Cir. 2004) (holding that an alleged inconsistency in a petitioner’s testimony could not serve as substantial evidence for an adverse credibility finding where the IJ “did not address at all [the petitioner’s] reasonable and plausible explanation” for the inconsistency). [1] The BIA made only passing and incomplete mention of Soto-Olarte’s explanations for the discrepa…
examined Cited as authority (rule) Soto-Olarte v. Holder (3×)
9th Cir. · 2009 · confidence medium
The BIA made only passing and incomplete mention of Soto-Olarte’s explanations for the discrepancies, noting that “[t]he respondents argue that this was a minor inconsistency or no consistency [sic] at all” but concluding that “[w]e disagree.” Because the BIA’s opinion does not refer to the explanation that Soto-Olarte gave, to the effect that police in Peru are reluctant to mention the Shining Path, and does not give the BIA’s reasons for considering that explanation unpersuasive, the BIA’s treatment of Soto-Olarte’s explanation does not satisfy our precedential requirement …
Retrieving the full opinion text from the archive…
99 Cal. Daily Op. Serv. 161, 98 Daily Journal D.A.R. 213 Leonardo Campos-Sanchez
v.
Immigration and Naturalization Service
97-70990.
Court of Appeals for the Ninth Circuit.
Jan 6, 1999.
164 F.3d 448
99 Cal. Daily Op. Serv. 161
1999 U.S. App. LEXIS 38
Nora Privitera, San Francisco, California, for petitioner., Frank W. Hunger, Karen Fletcher Tor-stenson, Timothy P. Mcllmail, Office of Immigration Litigation, United States Department of Justice, Washington, D.C., for respondent.
Farris, Reinhardt, Hawkins.
Cited by 219 opinions  |  Published
REINHARDT, Circuit Judge:

Leonardo Campos-Sanchez petitions this court for review of a final order of the Board of Immigration Appeals (“BIA”) denying his request for asylum and withholding of deportation. We conclude that the BIA erred in failing to provide Campos-Sanchez with a reasonable opportunity to offer explanations for alleged discrepancies between his testimony and his asylum application that formed the basis for its denial of asylum and withholding of deportation. Accordingly, we remand to the BIA so that it may afford Campos-Sanehez a hearing on credibility, and, if he is deemed credible, determine the merits of his claim for asylum. However, nothing herein shall preclude the BIA from deeming petitioner credible without a hearing.

Background

Campos-Sanchez, a native and citizen of Colombia, entered the United States on December 10, 1991 on a visitor’s visa. He overstayed his visit and applied for asylum and withholding of deportation pursuant to 8 U.S.C. secs. 1158(a) and 1253(h).

In his application for asylum and a sworn affidavit, Campos-Sanchez stated that he fled Colombia because members of guerrilla and narco groups threatened to kill him on account of his investigative work as a member of the Colombian Judicial Police. He states that because he was instrumental in developing intelligence information on drug traffickers, as well as active in investigating killings, bombings and other unlawful activities suspected to have been committed by subversive groups, he was well known in the communities in which he worked. He also states that two groups of his co-workers were attacked and killed by guerrillas, and that he received threatening phone calls making reference to these attacks, and telling him that he would be next.

The INS notified Campos-Sanchez of its intent to deny his application, based on its finding that he did not establish past persecution or a well-founded fear of future persecution on account of a protected ground. In its Intent to Deny Letter, the INS told Campos-Sanchez that his interview testimony was “detailed, specific, internally consistent and consistent with the written 1-589 application. You provided detailed answers to questions posed and your testimony also was consistent with known country conditions. The Service therefor finds your testimony credible.”

At the deportation hearing, Campos-Sanchez testified extensively about his work and the threats that he received against his life. The Immigration Judge (“IJ”), like the INS, expressly found Campos-Sanchez credible: “The Court has carefully observed the respondent’s testimony and demeanor. The Court is persuaded that' the respondent is credible and that what he has testified to could have happened in the manner in which he described it.” The IJ denied him asylum, however, because he found that Campos-Sanchez’s claim of persecution did not rise to the requisite level of a well-founded fear, and that his persecution was not on account of political opinion or membership in a particular social group.

Campos-Sanchez appealed the IJ’s decision to the BIA, asserting that the drug traffickers who threatened him imputed a pro-government political opinion to him, and that his police employment constituted membership in a particular social group for purposes of asylum. The BIA conducted an independent review of the record and identified a number of discrepancies between Campos-Sanehez’s testimony and his written submissions. The inconsistencies appear to be minor in nature. The BIA also noted a lack of corroborating evidence. It did not rely on the grounds relied on by the IJ; rather, it[*450] denied him asylum and withholding of deportation based solely on its adverse assessment of his credibility.

Campos-Sanchez seeks review of the BIA’s decision before this court, arguing that the BIA violated his right to due process by making an adverse credibility determination without affording him an opportunity to offer contrary evidence.

The Requirement of a “Full and Fair Hearing”

The Fifth Amendment guarantees due process in deportation proceedings. See Ramirez v. INS, 550 F.2d 560, 563 (9th Cir.1977). Under this Circuit’s case law, an alien must receive a “full and fair hearing,” in order to meet the requirements of due process. See, e.g., Castillo-Villagra v. INS, 972 F.2d 1017 (9th Cir.1992); Barraza Rivera v. INS, 913 F.2d 1443, 1447 (9th Cir.1990). In addition to the protections established by the Constitution and our case law, an alien’s right to a full and fair hearing is also protected by specific statutory and regulatory provisions. See, e.g., 8 U.S.C. sec. 1252(b), 8 C.F.R. sec. 242.16(a)(aliens must be provided. reasonable opportunity to present testimony in their own behalf); 8 C.F.R. sec. 208.10(b) (aliens must have opportunity to inspect and rebut an advisory opinion from the State Department). If the prejudice to the alien is sufficiently great, denial of the right to a full and fair hearing may violate the constitutional guarantee of due process. See Barraza Rivera, 913 F.2d at 1447. This court has found prejudice where an alien’s rights are violated “in a manner so as potentially to affect the outcome of the proceedings.” United States v. Cerda-Pena, 799 F.2d 1374, 1379 (9th Cir.1986).

In this case, the BIA independently reviewed the record and made an adverse credibility finding, which formed the sole basis for its denial of Campos-Sanchez’s appeal. The BIA’s opinion states that “[n]o explanation for the numerous discrepancies between the various versions has been offered.” AR 4. Campos-Sanchez, however, had not been advised below that his credibility was questionable, or that any discrepancies appeared to exist; nor was he asked to explain any such perceived discrepancies. Quite the contrary, both the INS and the IJ expressly found Campos-Sanchez to be credible. See AR 132 (INS Intent to Deny Letter); AR 34-35 (IJ’s credibility finding). Thus, Campos-Sanchez had no notice of the inconsistencies perceived by the BIA, and no opportunity to explain them.

In this court’s cases reviewing adverse credibility determinations made by the BIA, we have required that, in order to ensure a fair hearing, the BIA not only identify specific inconsistencies, but also “address in a reasoned manner the explanations that [petitioner] offers for these perceived inconsistencies.” Osorio v. INS, 99 F.3d 928, 931 (9th Cir.1996) (emphasis added). “[I]nconsis-teneies of less than substantial importance for which a plausible explanation is offered” cannot form the sole basis for an adverse credibility finding. Garrovillas v. INS, 156 F.3d 1010, 1013-14 (9th Cir.1998). See also Vilorio-Lopez v. INS, 852 F.2d 1137 (9th Cir.1988) (minor inconsistencies cannot serve as sole basis for adverse credibility finding). The logical corollary to the requirement that the BIA must address the explanations offered by a petitioner is that the BIA must provide a petitioner with a reasonable opportunity to offer an explanation of any perceived inconsistencies that form the basis of a denial of asylum.

To deny Campos-Sanchez an opportunity to be heard in these circumstances was a denial of the “full and fair hearing” required by the Fifth Amendment and this Circuit’s case law regarding fair deportation proceedings. When the BIA decides a case based on an independent, adverse, credibility determination, contrary to that reached by the IJ, it must give the petitioner an opportunity to explain any alleged inconsistencies that it raises for the first time. This matter is remanded for proceedings at which Campos-Sanchez may respond to the perceived inconsistencies, offer explanations, and be heard on his credibility, unless the BIA decides without further formal proceedings that[*451] his testimony is credible. [1]

REVERSED and REMANDED.

1

. We note also that if the BIA finds the petitioner credible on remand, it should not require corrob-' orating documents in order to establish his claim of a well-founded fear of persecution. Our cases are clear that such corroboration is encouraged but not required. See, e.g., Garrovillas, 156 F.3d at 1016-17 (corroborative evidence is not necessary for a petitioner to establish past persecution); Sangha v. INS, 103 F.3d 1482, 1487 (9th Cir.1997) ("Because asylum cases are inherently difficult to prove, an applicant may establish his case through his own testimony alone”); Aguilera-Cota v. INS, 914 F.2d 1375, 1379 (9th Cir.1990) (recognizing that refugees frequently do not possess documentary evidence regarding events related to persecution).