What is the current state of the law in the 9th Circuit when it comes to denying denial of withholding of deportation?

This circuit makes it easier than any other for an alien to argue successfully that a decision by an immigration judge is not supported by substantial evidence. The seed that yielded this fruit was Bolanos-Hernandez v. INS, 767 F.2d 1277, 1282 n. 8 (9th Cir.1984), in which this court began to review denials of withholding of deportation under a "heightened" substantial evidence standard. The reason offered for the departure was that where the issue is withholding deportation, a finding of a "probability" of persecution required granting the relief, whereas the granting of asylum was a matter within the discretion of the Attorney General. Id. and n. 9. Whatever may be the merits of this distinction, the "hydraulics" of the "withholding of deportation" and "asylum" provisions dictate that reducing the level of the first forces a lowering of the second.