The following excerpt is from Arana-Guadamuz v. I.N.S., 72 F.3d 135 (9th Cir. 1995):
The standard for withholding deportation is less generous than the standard for asylum. INS v. Cardoza-Fonseca, 480 U.S. 420, 444 (1987). Thus, having failed to satisfy the lower burden of proof required for asylum, petitioner necessarily fails to satisfy the stricter burden required for withholding deportation.
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