Immigrant serves five-year sentence after 1992 drug conviction but isn’t deported because Iraq isn’t issuing travel papers. He’s rearrested in 2017 after Iraq begins issuing such papers. Immigrant: I’m a Chaldean Christian; it’s not safe for me there. Board of Immigration Appeals: You didn’t provide sufficient evidence that you’ll be tortured by the Iraqi gov’t or with its acquiescence. Sixth Circuit: We don’t have jurisdiction to review the BIA’s factual determinations.