What is the current state of the law on withholding of removal?

Sufficiency of existing procedures. The existing procedures give the alien substantial protections. The alien first submits a written application for withholding of removal, and then gets a hearing at which he has the right to present evidence; call his own witnesses; and cross-examine adverse witnesses. See8 U.S.C. 1229a(b)(4)(B); 8 C.F.R. 1240.10(a)(4), 1240.11(c)(3)(iii). Should he require documents not readily available to him, he may apply to the immigration judge for a subpoena. See8 C.F.R. 1003.35(b)(1). He has the privilege of being represented by counsel. See8 U.S.C. 1229a(b)(4)(A). After the hearing, the alien may be permitted to submit additional briefing to supplement his file. See Somakoko v. Gonzales, 399 F.3d 882, 883 (8th Cir.2005).