2 canonical passages across 2 cases, quoted by 7 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Nikijuluw v. Gonzales.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Nikijuluw v. Gonzales Anchor | green | “add up to more than mere discomfiture, unpleasantness, harassment, or unfair treatment.” | 4 |
| 2 | Rodriguez-Ramirez v. Ashcroft | green | “more stringent burden of proof on an alien than does a counterpart claim for asylum.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.