The following excerpt is from Mabitad v. I.N.S., 134 F.3d 378 (9th Cir. 1997):
Mabitad's failure to qualify for asylum necessarily precludes her qualification for withholding of deportation, since withholding of deportation requires a higher standard of proof See, e.g., Ghaly v. INS, 58 F.3d 1425, 1429 (9th Cir.1995).
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