Jamal Ali Farah v. John Ashcroft, Attorney Gen., 348 F.3d 1153 (9th Cir. 2003). · Go Syfert
Jamal Ali Farah v. John Ashcroft, Attorney Gen., 348 F.3d 1153 (9th Cir. 2003). Cases Citing This Book View Copy Cite
4,257 citation events (4,244 in the last 25 years) across 7 distinct courts.
Strongest positive: Gustavo Maravilla-Pineda v. Pamela Bondi (ca9, 2026-03-18) · Strongest negative: Jaspreet Singh v. William Barr (ca9, 2020-07-15)
Treatment trajectory · 2003 → 2026 · click a year to view as-of
2003 2014 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Distinguished Jaspreet Singh v. William Barr
9th Cir. · 2020 · signal: see also · confidence high
See 8 U.S.C. §§ 1158 (b)(1)(B)(ii)–(iii) (outlining credibility criteria for asylum applicants), 1231(b)(3)(C) (same for withholding of removal); see also Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003) (allowing lack of credibility to suffice for denial of CAT protection where underlying allegations are indistinguishable from those supporting asylum and withholding of removal applications).
discussed Cited as authority (verbatim quote) Gustavo Maravilla-Pineda v. Pamela Bondi (2×) also: Cited "see"
9th Cir. · 2026 · quote attribution · 1 verbatim quote · confidence high
because we affirm the bia's determination that failed to establish eligibility for asylum, we also affirm the denial of application for withholding of removal.
discussed Cited as authority (verbatim quote) Deyu Lu v. Merrick Garland
9th Cir. · 2021 · quote attribution · 1 verbatim quote · confidence high
ecause we affirm the bia's determination that farah and his witnesses were not credible, we must similarly affirm the rejection of farah's claim under the convention against torture.
discussed Cited as authority (verbatim quote) Fei Wang v. Merrick Garland
9th Cir. · 2021 · quote attribution · 1 verbatim quote · confidence high
ecause we affirm the bia's determination that farah and his witnesses were not credible, we must similarly affirm the rejection of farah's claim under the convention against torture.
discussed Cited as authority (verbatim quote) Rakibul Hassan v. Merrick Garland
9th Cir. · 2021 · quote attribution · 1 verbatim quote · confidence high
because we affirm the bia's determination that farah and his witnesses were not credible, we must similarly affirm the rejection of farah's claim under the convention against torture.
examined Cited as authority (verbatim quote) Lianhua Jiang v. Eric Holder, Jr. (8×) also: Cited as authority (rule), Cited "see"
9th Cir. · 2014 · signal: see · quote attribution · 2 verbatim quotes · confidence high
because we affirm the bia's determination that farah failed to establish eligibility for asylum, we also affirm the denial of farah's application for withholding of removal.
discussed Cited as authority (verbatim quote) Remi Louis v. Eric Holder, Jr. (2×) also: Cited as authority (rule)
9th Cir. · 2013 · quote attribution · 1 verbatim quote · confidence high
a failure to establish eligibility for asylum does not necessarily doom an application for relief under
discussed Cited as authority (verbatim quote) Kmet v. Holder
9th Cir. · 2011 · signal: see · quote attribution · 1 verbatim quote · confidence high
us and the bia are not free to ignore arguments raised by .
discussed Cited as authority (quoted) Kumar v. Blanche
9th Cir. · 2026 · signal: see · quote attribution · 1 verbatim quote · confidence high
in this case . . . claims under the convention against torture are based on the 3 25-1393 same statements . . . that the bia determined to be not credible.
discussed Cited as authority (quoted) Singh v. Bondi
9th Cir. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
in this case . . . claims under the convention against torture are based on the same statements . . . that the bia determined to be not credible.
discussed Cited as authority (quoted) Rosales Martinez v. Garland (2×) also: Cited "see"
9th Cir. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
because we affirm the bia's determination that farah failed to establish eligibility for asylum, we also affirm the denial of farah's application for withholding of removal.
discussed Cited as authority (rule) Dhavle v. Blanche
9th Cir. · 2026 · confidence medium
The agency may conclude that such documentary evidence is 3 “entitled to limited weight” where, inter alia, “the affidavit[s] and letters provided [are] from interested parties,” Mukulumbutu v. Barr, 977 F.3d 924, 927 (9th Cir. 2020); where those parties are not “available for cross-examination,” id.; where the documents “do not reveal any independent knowledge of [the] alleged abuse,” Garcia v. Holder, 749 F.3d 785, 791 (9th Cir. 2014); or where “the authenticity of the documents relie[s] on [a petitioner’s] discredited testimony,” id. “[W]hile ineligibility for asylum…
discussed Cited as authority (rule) Si v. Blanche
9th Cir. · 2026 · confidence medium
In the absence of credible testimony or sufficient independent corroborating evidence, the record does not compel us to reach a conclusion contrary to the determination that 3 25-2868 Petitioners did not establish eligibility for asylum.2 See Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). 2.
discussed Cited as authority (rule) Olivarez Morales v. Blanche
9th Cir. · 2026 · confidence medium
Under this standard, review is “extremely deferential,” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003), and the evidence must “compel[] a contrary conclusion from that adopted by the BIA,” Parada v. Sessions, 902 F.3d 901, 909 (9th Cir. 2018). “[W]e may not reweigh the evidence to determine for ourselves whether Petitioner faced persecution”; instead, “[w]e merely determine whether the evidence compels such a conclusion.” See Singh v. I.N.S., 134 F.3d 962 , 969 n.14 (9th Cir. 1998).
cited Cited as authority (rule) Singh v. Blanche
9th Cir. · 2026 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
cited Cited as authority (rule) Singh v. Blanche
9th Cir. · 2026 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
discussed Cited as authority (rule) Juan Ramirez Juan v. Pamela Bondi
9th Cir. · 2026 · confidence medium
Under the substantial evidence standard, the agency’s findings are “conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.” Velasquez-Gaspar v. Barr, 976 F.3d 1062, 1064 (9th Cir. 2020) (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)).
discussed Cited as authority (rule) Zhanhui Xu v. Pamela Bondi
9th Cir. · 2026 · confidence medium
The IJ “established a legitimate, articulable basis to question [Xu’s] credibility and offered specific, cogent reasons for disbelief as required under our law.” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
discussed Cited as authority (rule) Singh v. Bondi (2×) also: Cited "see"
9th Cir. · 2026 · confidence medium
We cannot say that “the evidence that the petitioner presented was ‘so compelling that no reasonable factfinder could find that [the petitioner] was not credible.’” Malkandi v. Holder, 576 F.3d 906, 917 (9th Cir. 2010) (alteration in original) (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)). 2.
discussed Cited as authority (rule) Nelly Fiallos-Munoz v. Pamela Bondi (2×) also: Cited "see"
9th Cir. · 2026 · confidence medium
We “reverse the BIA’s [credibility] decision only if the petitioner’s evidence was ‘so compelling that no reasonable factfinder could find that [s]he was not credible.’” Kin v. Holder, 595 F.3d 1050, 1054 (9th Cir. 2010) (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)).
discussed Cited as authority (rule) Mateo Mateo v. Bondi
9th Cir. · 2025 · confidence medium
Substantial evidence is an extremely deferential standard, requiring the petitioner to “establish that the evidence not only supports that conclusion, but compels it.” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003) (citation omitted).
discussed Cited as authority (rule) Jesus Tomas Gaspar v. Pamela Bondi
9th Cir. · 2025 · confidence medium
We examine the BIA’s factual findings for substantial evidence, taking “such findings as ‘conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.’” Id. (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)). 1.
discussed Cited as authority (rule) Garcia-Aguilar v. Bondi
9th Cir. · 2025 · confidence medium
We examine the BIA’s factual findings for substantial evidence, taking “such findings as ‘conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.’” Id. (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)). 1.
cited Cited as authority (rule) Singh v. Bondi
9th Cir. · 2025 · confidence medium
That standard is “extremely deferential.” Velasquez- Gaspar v. Barr, 976 F.3d 1062, 1064 (9th Cir. 2020) (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)).
discussed Cited as authority (rule) Chilel-Escobar De Ujpan v. Bondi
9th Cir. · 2025 · confidence medium
The IJ properly considered the “totality of the circumstances,” 8 U.S.C. § 1158 (b)(1)(B)(iii), and rested her determination on two permissible grounds: (1) the inconsistency between Chilel’s testimony that she decided to leave Guatemala after being threatened by five men in person at her house, and the statement in Chilel’s affidavit that she fled after receiving a threatening phone call; and (2) the inconsistency between Chilel’s testimony that her husband’s death was 2 24-1744 caused by a severe beating, and the death certificate listing his sole cause of death as “hepatic ci…
cited Cited as authority (rule) Portillo v. Bondi
9th Cir. · 2025 · confidence medium
See Mukulumbutu v. Barr, 977 F.3d 924, 927 (9th Cir. 2020); Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). 3.
discussed Cited as authority (rule) Lu v. Garland
9th Cir. · 2024 · confidence medium
Because “[t]hese credibility findings went to key elements” of Lu’s applications for asylum, withholding of removal, and protection under CAT, “[w]e must defer to the IJ’s credibility findings and uphold the denial of [these forms of] relief.” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
discussed Cited as authority (rule) Jeronimo-Jeronimo v. Garland
9th Cir. · 2024 · confidence medium
See id.; Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003) (finding that petitioner had not credibly established identity and upholding denial of CAT claim on that basis).
discussed Cited as authority (rule) Benitez-De Lopez v. Garland (2×)
9th Cir. · 2024 · confidence medium
Where, as here, “the BIA adopts and affirms the IJ’s decision by citing Matter of Burbano, [ 20 I. & N. Dec. 872 (B.I.A. 1994),] it is adopting the IJ’s decision in its entirety,” Lezama-Garcia v. Holder, 666 F.3d 518, 524 (9th Cir. 2011), and we review the IJ’s decision as if it were that of the BIA, Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
cited Cited as authority (rule) Pablo Calmo v. Garland
9th Cir. · 2024 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). 3.
discussed Cited as authority (rule) Carmen Orozco Guzman v. Merrick Garland
9th Cir. · 2024 · confidence medium
See Rodriguez-Ramirez v. Garland, 11 F.4th 1091 , 1093– 94 (9th Cir. 2021) (finding absence of credible testimony alone supported denial of asylum and withholding claims); Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003) (an adverse credibility finding may be dispositive as to asylum and withholding). 6 CAT 5.
cited Cited as authority (rule) Torres Torres v. Garland
9th Cir. · 2024 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
cited Cited as authority (rule) Samayoa Rodriguez v. Garland
9th Cir. · 2024 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). 4.
discussed Cited as authority (rule) Li v. Garland
9th Cir. · 2024 · confidence medium
Under this standard, we will uphold the BIA’s adverse credibility determination unless the petitioner's evidence was “so compelling that no reasonable factfinder could find that he was not credible.” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir.2003) (internal quotation omitted).
discussed Cited as authority (rule) Baoguo Liu v. Merrick Garland
9th Cir. · 2024 · confidence medium
I write separately to state that this disposition should not be construed as weakening the principle that “failure to establish eligibility for asylum does not necessarily doom an application for relief under the United Nations Convention Against Torture.” Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
discussed Cited as authority (rule) Eric Hermosillo v. Merrick Garland
9th Cir. · 2023 · confidence medium
GARLAND 17 BENNETT, Circuit Judge, dissenting in part: I respectfully dissent from the majority’s decision to grant the petition as to the immigration judge’s (IJ) finding that Eric Blancas Hermosillo lacks a reasonable fear of persecution for failure to establish a nexus to a protected ground.1 The substantial evidence standard is “extremely deferential.” Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
discussed Cited as authority (rule) Yan Jin v. Merrick Garland
9th Cir. · 2023 · confidence medium
We evaluate factual findings under an “extremely deferential” standard, Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003), imposed by Congress: “administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary,” 8 U.S.C. § 1252 (b)(4)(B).
discussed Cited as authority (rule) Ud Din v. Garland
2d Cir. · 2023 · confidence medium
See, e.g., Ning Wang v. Lynch, 845 F.3d 299, 300 (7th Cir. 2017) (denying petition “with regard to the denial of [petitioner’s] applications for immigration relief” but granting petition “with regard to the finding of frivolousness”); Limbeya v. Holder, 764 F.3d 894, 896 (8th Cir. 2014) (leaving intact removal order but “remand[ing] for further proceedings on the issue of frivolousness”); Mingkid v. U.S. Att’y Gen., 468 F.3d 763 , 768–69 (11th Cir. 2006) (rejecting mootness argument because vacating frivolousness finding “incontrovertibly leaves [petitioners] in better posi…
cited Cited as authority (rule) Lawridan Asongtia v. Merrick Garland
9th Cir. · 2023 · confidence medium
See 8 C.F.R. §§ 1208.13 (a), 1208.16(b)(2); Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). a.
cited Cited as authority (rule) Toloza Ibarra v. Garland
9th Cir. · 2023 · confidence medium
See Rodriguez- Ramirez v. Garland, 11 F.4th 1091 , 1094 (9th Cir. 2021); Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003). 3.
discussed Cited as authority (rule) Asghar v. Garland
9th Cir. · 2023 · confidence medium
For example, responding to the government attorney’s presentation of social media posts suggesting that Asghar may have made misleading statements about his visits to Russia, Asghar appears to grow increasingly frustrated. 3 21-1290 Under the “extremely deferential” substantial evidence standard, Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003), we are not “compelled to conclude” that the agency erred in its adverse credibility determination. 8 U.S.C. § 1252 (b)(4)(B). 2.
discussed Cited as authority (rule) Akam v. Garland (2×) also: Cited "see"
9th Cir. · 2023 · confidence medium
Under the substantial evidence standard, to overcome the BIA’s adverse credibility determination, the record must be “so compelling that no reasonable factfinder could find that [the petitioner] was not credible.” Kin v. Holder, 595 F.3d 1050, 1054 (9th Cir. 2010) (quoting Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003)).
cited Cited as authority (rule) Lu v. Garland
9th Cir. · 2023 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
discussed Cited as authority (rule) Fidelis Nkenganyi v. Merrick Garland
9th Cir. · 2023 · confidence medium
“It is important to keep in mind that the CAT standard is ‘distinct’ from that of asylum and the two bases for relief ‘should not be conflated.’” Udo v. Garland, 32 F.4th 1198, 1202 (9th Cir. 2022) (quoting Farrah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003)).
cited Cited as authority (rule) David Singh v. Merrick Garland
9th Cir. · 2023 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
discussed Cited as authority (rule) Winston Gutierrez-Alm v. Merrick Garland
9th Cir. · 2023 · confidence medium
Gutierrez seeks withholding of removal under both asylum law and the Convention Against Torture. “[T]he standards for the two bases of relief are distinct and should not be conflated.” Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
cited Cited as authority (rule) Gonzalo Mendoza Matias v. Merrick Garland
9th Cir. · 2022 · confidence medium
Farrah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
cited Cited as authority (rule) Santos Alverez Vasquez v. Merrick Garland
9th Cir. · 2022 · confidence medium
Aguilar Fermin v. Barr, 958 F.3d 887 , 892–93 (9th Cir. 2020); Farah v. Ashcroft, 348 F.3d 1153, 1156 (9th Cir. 2003).
cited Cited as authority (rule) Peter Udo v. Merrick Garland
9th Cir. · 2022 · confidence medium
Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003).
discussed Cited as authority (rule) Edward Marroquin-Sanchez v. Merrick Garland
9th Cir. · 2022 · confidence medium
However, the agency may deny CAT relief based on an adverse credibility determination developed in the asylum context if “a petitioner’s ‘claims under the [CAT] are based on the same statements . . . that the BIA determined to be not credible’ in the asylum context.” Id. (quoting Farah v. Ashcroft, 348 F.3d 1153, 1157 (9th Cir. 2003)).
Retrieving the full opinion text from the archive…
Jamal Ali FARAH, Petitioner,
v.
John ASHCROFT, Attorney General, Respondent
02-70252.
Court of Appeals for the Ninth Circuit.
Nov 14, 2003.
348 F.3d 1153
Cheri Attix, Law Office of Cheri Attix, San Diego, CA, for the petitioner., Stephen J. Flynn and Jacqueline R. Dryden, Office of Immigration Litigation, Civil Division, U.S. Department of Justice, Washington, DC, for the respondent.
Schroeder, Thompson, Graber.
Cited by 2,870 opinions  |  Published
3 passages pin-cited by 3 cases
Pinpoint authority: #45,313 of 633,719
Citer courts: Ninth Circuit (2)
SCHROEDER, Chief Judge.

Petitioner, Jamal Ali Farah, petitions for review of the BIA’s decision denying his application for asylum and adopting the opinion of the immigration judge (“IJ”). The IJ had ordered Farah removed on the basis of the finding that Farah was not credible and had further ordered Farah permanently ineligible for any benefits under the immigration laws of the United States because his application was frivolous. See 8 U.S.C. § 1158(d)(6).

In this petition for review, Farah first challenges the IJ’s credibility determination underlying his removal order. Farah, however, bears a heavy burden, for he is required to establish that the evidence was so compelling that this court must find it worthy of credence and must order him eligible for asylum relief. INS v. Elias-Zacarias, 502 U.S. 478, 483-84, 112 S.Ct. 812, 117 L.Ed.2d 38 (1992). Farah has not borne this burden.

Farah also challenges the IJ’s finding that he knowingly filed a frivolous asylum application. Such a finding carries the severe penalty of a permanent bar to immigration relief, so, INS regulations require there to be sufficient opportunity to account for discrepancies or implausibilities. 8 C.F.R. § 208.20. Our research discloses no case in which we have upheld such a bar, and we agree with petitioner that the IJ’s finding was infirm for failure to follow the requirements of that regulation. We therefore affirm the order of removal but vacate the- order of permanent ineligibility for immigration benefits under section 208(d)(6) of the Immigration and Nationality Act (the “Act” or “INA”). [1]

[*1155] I. Background:

Farah, a citizen of Somalia, stated in his asylum application that he arrived in New York on January 24, 1999, using concededly false travel documents, and then transferred immediately to a flight to San Diego. He filed his application for asylum with the INS on February 16, 1999, conceding removability at his hearing before the IJ on April 27, 1999.

In his asylum application, Farah asserted eligibility for asylum because of past persecution on account of membership in a particular group, his clan. He further stated that he fears future persecution by the United Somali Congress (the “USC”) if he returns to Somalia. His application stated that the USC looted his family’s business and attacked his family home as part of an orchestrated plan of ethnic cleansing. According to his application, the USC militiamen shot his two cousins and knocked him unconscious because he and his family are members of the Meheri clan.

At the hearing, Farah, his alleged half-brother, Ahmed Ali Farah, and his expert witness on Somalia, Dr. Asha Samad, all testified concerning Farah’s clan and his identity. Dr. Samad stated that Farah is from the “Meheri Ismail” clan and that Farah’s father’s name was “Ali Farah Ma-hamoud Ismail.” Farah, however, testified that his father’s name was “Ali Farah Abdi.” Later Dr. Samad clarified that Fa-rah’s father’s full name was “Ali Farah Abdi Farah Mahamoud Ismail Mahamoud Saleh” and that Farah’s father would be known as “Ali Farah Abdi.” The IJ found that Dr. Samad’s testimony was inconsistent.

Farah’s alleged half-brother, Ahmed Ali Farah, testified that his father’s name was “Ali Farah Abdi,” although on his own application he had listed “Ali Farah Ali” as his father. He explained that at the hearing as a clerical error. Farah’s half-brother also listed a different clan association than the “Meheri” in his application, and he did not identify Jamal Farah as a sibling on the application. At the hearing, the half-brother explained that, when he filed for asylum, he listed his clan as traced from his mother’s patrilineal descent, not his father’s, and that he did not include Farah as a sibling because, unlike Farah’s application, his application was derivative of his mother’s clan, not his father’s. The IJ also found the half-brother’s testimony inconsistent and lacking credibility.

Additionally, Farah’s alleged half-brother testified that, after Farah arrived in San Diego, the half-brother sent Farah their father’s identification card for use in Farah’s asylum application. The IJ, however, doubted whether, if Farah arrived in the United States on January 24, he could have filed his asylum application on February 16. The IJ concluded that Farah was not credible in claiming that he navigated through a foreign country and language, found a place to live, and filed an asylum application within that short period of time.

At the conclusion of Farah’s initial appearance, the IJ reviewed the penalties for[*1156] filing a frivolous application with Farah, and Farah indicated he understood the penalties and desired to go forward. During the course of the proceedings, the IJ did not, however, go through specific inconsistencies or implausible elements of Farah’s claim, upon which the frivolousness finding relied, and did not give Farah an opportunity to explain them.

Eventually, the IJ entered an order setting forth his findings and his overall adverse credibility determination. The IJ further concluded that Farah had received notice under section 208(d)(4) of the Act and had knowingly made a frivolous application for asylum. The IJ ordered Farah’s removal to Somalia and denied requests for asylum, withholding of removal, and relief under the United Nations Torture Convention. The IJ ordered that Farah be permanently ineligible for any benefits under the immigration laws.

The BIA reviewed the administrative record and then entered a summary order adopting, and affirming the IJ’s decision in its entirety, dismissing the appeal in an order dated May 9, 2001. This petition followed.

II. Discussion:

Where the BIA adopts the findings and reasoning of the IJ, this court reviews the decision of the IJ as if it were that of the BIA. Al-Harbi v. INS, 242 F.3d 882, 887 (9th Cir.2001). The standard of review is extremely deferential: “administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(A)-(B). Thus, when a petitioner contends that the IJ’s findings are erroneous, the petitioner “must establish that the evidence not only supports that conclusion, but compels it.” Singh v. INS, 134 F.3d 962, 966 (9th Cir.1998) (citation and internal quotation omitted).

The same standard applies to the IJ’s credibility findings. Chebchoub v. INS, 257 F.3d 1038, 1042 (9th Cir.2001); Prasad v. INS, 47 F.3d 336, 338 (9th Cir.1995). Thus, this court must deny Farah’s petition unless Farah has presented evidence “so compelling that no reasonable factfin-der could find” that he was not credible. Garrovillas v. INS, 156 F.3d 1010, 1015-16 (9th Cir.1998); see also Elias-Zacarias, 502 U.S. at 483-84, 112 S.Ct. 812.

Here, the IJ established a legitimate, articulable basis to question Farah’s credibility and offered specific, cogent reasons for disbelief as required under our law. See Shah v. INS, 220 F.3d 1062, 1067 (9th Cir.2000). These credibility findings went to key elements of the asylum application, including identity, membership in a persecuted group, and date of entry in the United States. Eligibility for asylum depends on the credible establishment of these elements. 8 U.S.C. § 1158(d)(5)(A)(i). We must defer to the IJ’s credibility findings and uphold the denial of asylum relief.

Because we affirm the BIA’s determination that Farah failed to establish eligibility for asylum, we also affirm the denial of Farah’s application for withholding of removal. See Pedro-Mateo v. INS, 224 F.3d 1147, 1150 (9th Cir.2000) (“A failure to satisfy the lower standard of proof required to establish eligibility for asylum therefore necessarily results in a failure to demonstrate eligibility for withholding of deportation.”)(internal citation omitted).

A failure to establish eligibility for asylum does not necessarily doom an application for relief under the United Nations Convention Against Torture, however. In Kamalthas v. INS, 251 F.3d 1279, 1282-83 (9th Cir.2001), we expressly rejected the BIA’s determination that an “‘applicant [fails] to satisfy his burden of presenting a[*1157] prima facie case for relief under the Convention where he merely restates facts that have already been deemed incredible at a prior [asylum] hearing’ ” (alteration in original). Instead, we held that the standards for the two bases of relief are distinct and should not be conflated. We explained that, “pursuant to 8 C.F.R. § 208.16(c)(3), ‘all evidence relevant to the possibility of future torture shall be considered,’ even apart from any prior findings in the asylum context.” Id. at 1283. In that case, we particularly pointed to the fact that “nowhere in its opinion did the BIA consider the documented country conditions in Sri Lanka which corroborate the widespread practice of torture against Tamil males.” Id.

In this case, by contrast, Farah’s claims under the Convention Against Torture are based on the same statements, by Farah and others, that the BIA determined to be not credible. Farah points to no other evidence that he could claim the BIA should have considered in making its determination under the Convention Against Torture. Therefore, because we affirm the BIA’s determination that Farah and his witnesses were not credible, we must similarly affirm the rejection of Fa-rah’s claim under the Convention Against Torture.

The IJ also concluded, however, that Farah’s asylum application was so inconsistent that it rose to the level of being knowingly frivolous; such a finding is a permanent bar to relief under the immigration laws. INA § 208(d)(4), (d)(6); 8 U.S.C. § 1158(d)(4), (d)(6). This court has apparently never recognized, in any published opinion, a finding under § 1158(d)(6) of a frivolously filed asylum application. The closest authority is from the Fifth and Eleventh Circuits. Efe v. Ashcroft, 293 F.3d 899 (5th Cir.2002); Barreto-Claro v. United States Attorney Gen., 275 F.3d 1334 (11th Cir.2001). These cases reaffirm the importance, as required by regulation, of the applicant’s receiving an opportunity to explain any discrepancies in the testimony before a finding of frivolousness — -permanently barring immigration relief — is entered. Efe, 293 F.3d at 908; Barreto-Claro, 275 F.3d at 1339; see also 8 C.F.R. § 208.20 (“Such finding shall only be made if the [IJ] or [BIA] is satisfied that the applicant, during the course of the proceedings, has had sufficient opportunity to account for any discrepancies or implausible aspects of the claim.”).

In Efe, the Fifth Circuit recently affirmed an IJ’s finding that the petitioner had knowingly filed a frivolous asylum application with intentionally false statements. See Efe, 293 F.3d at 908. The petitioner had misled the court about his age by providing inconsistent answers regarding his age at his alleged time of entry in response to different questions asked in the course of the proceedings. Important to the frivolousness determination was the evidence of dental records that revealed the petitioner’s true age to a significant degree of certainty. Id. at 902 n. 1. The court stressed that the petitioner had ample opportunity to clarify his contradictory testimony and did not satisfactorily do so. Id. at 908.

In Barreto-Claro, the Eleventh Circuit affirmed the BIA’s “strict, no tolerance statutory interpretation, that applicants must tell the truth or be removed,” and upheld a finding of knowing frivolousness. Barreto-Claro, 275 F.3d at 1339. The petitioner, a Cuban national, had filed an original asylum application stating that he traveled directly to the United States from Cuba. Id. at 1336. Then the petitioner filed a second application admitting that he lied in his first application. The Eleventh Circuit stressed that the petitioner essentially did not argue that his fraudulent[*1158] statements were not material nor knowingly made, but instead argued why he lied, i.e., as the court described it, “ ‘why con-cededly material fabrications were knowingly made.’ ” Id. at 1339 (court quoting the BIA). The court emphasized that the BIA had been satisfied that the petitioner was given sufficient opportunity to account for any discrepancies or implausible aspects of his claim, and the petitioner did not challenge the materiality or scienter elements of the finding of a knowingly filed frivolous asylum application. Id.

In this case, the IJ found two specific examples of fabrication that were relevant to his decision: the petitioner’s entry date and his travel history. In his decision, the IJ held:

It is clear to this Court the respondent did not enter in New York on January 24, 1999, in the manner in which he stated. He has fabricated that portion of his claim, He has also been untruthful as to whether he was in Nairobi, Kakuma, London, England or any other place before he came to the United States.

Farah had ample opportunities to explain the discrepancies that led to the adverse credibility finding — for example, discrepancies in his father’s name and in his clan identity. To support the finding of frivolousness, however, the IJ relied with particularity on different discrepancies between what Farah said and the extrinsic evidence. Fa'rah was not given an adequate opportunity to address those additional discrepancies before the ruling on frivolousness was made. 8 U.S.C. § 1158(d)(6); Efe, 293 F.3d at 908; Barreto-Claro, 275 F.3d at 1339; 8 C.F.R. § 208.20.

In sum, the evidence presented does not compel this court to find Farah’s evidence was worthy of belief, and we defer to the factfinder’s adverse credibility determination. The absence of a proper opportunity for Farah to explain all discrepancies in the record, however, requires us to overturn the conclusion that the application was knowingly frivolous.

Farah’s petition for review of the BIA’s decision is DENIED as to the denial of asylum eligibility, but GRANTED as to the finding that his application was frivolous.

Petition GRANTED in part, DENIED in part, and REMANDED.

1

. Section 208(d) of the Act, 8 U.S.C. § 1158(d), provides in relevant part:

(d) Asylum procedure

(4) Notice of privilege of counsel and consequences of frivolous application

At the time of filing an application for asylum, the Attorney General shall—

[*1155] (A) advise the alien of the privilege of being represented by counsel and of the consequences, under paragraph (6), of knowingly filing a frivolous application for asylum; and

(B) provide the alien a list of persons (updated not less often than quarterly) who have indicated their availability to represent aliens in asylum proceedings on a pro bono basis.

(6) Frivolous applications If the Attorney General determines that an alien has knowingly made a frivolous application for asylum and the alien has received the notice under paragraph (4)(A), the alien shall be permanently ineligible for any benefits under this chapter, effective as of the date of a final determination on such application.