Paterko v. Holder
Opposition to corruption may possess a political dimension, if the opposition transcends mere self-protection and constitutes a challenge to the ruling regime's authority, purusant to Yueqing Zhang v. Gonzales, a 2005 decision of the 2nd Circuit. The petitioner, a citizen of the Ukraine, applied for asylum, withholding of removal and relief under the Convention Against Torture. Immigration Judge Michael Straus found that the petitioner failed to establish persecution took place because of the petitioner's political opinion and denied his application. The Board of Immigration Appeals affirmed. Allegedly, the petitioner was abducted and beaten, because he demanded payment on a contract from an official in Ukraine. The petitioner failed to establish this constituted a political dispute, as opposed to a monetary one. Unlike the petitioner in Yueqing Zhang v. Gonzales, here the petitioner did not organize local business leaders in opposition to corruption. The petitioner merely established that he allegedly opposed the activities of one corrupt government official, and the 2nd Circuit denied the petition for review.