DETERMINING ASYLUM CLAIMS IN THE UNITED STATES: AN EMPIRICAL CASE STUDY The Implementation of Legal Norms in an Unstructured Adjudicatory Environment By Deborah E. Anker Executive Summary January 1990 Final Report April 1991 This Report is being prepared for publication in Volume 19 of the New York University School of Law Journal of Law and Social Change. 302838467+ "One of the matters that has conncered me greatly about the admission of refugees and persons who seek asylum is the fact that there really are no specific procedures that would assure that due process is granted when such persons are questioned in ordeor [t] determine 0 whether or not they meet the present statutory standards. . . . "[W]hen Congress creates a statutory scheme and does not really specify how that scheme is to be implemented it can be thwarted by the executive branch. ... [Although Ithink the definition in this bill is an excellent one and even though it states . . .[t hat a person] will be a refugee if he or she has a well-founded fear of persecution , we don't specify how that well-founded fear is to be ascertained, or whether a person has a right to be questioned about the presence or absence of that well-founded fear in his or her own language. Don't you agree that the method by which a determination as to whether or not someone is a refugee is made should be spelled out in some detail?" Hearings on Refugee Act Representative Elizabeth Holtzman Co-Sponsor, Refugee Act of 1980 "...[The agency's] previous interpretation of the [well-founded fear standard] is... strikingly contrary to plain language and legislative history.... The efforts of [the circuit courts] stand in stark contrast to—but, it's sad to say, alone cannot make up for— the years of seemingly purposeful blindness by the [administrative agency], which only now begins its task of developing the standard entrusted to its care." Justice Blackman, concurring in INS v. Cardoza-Fonseca 1987 (overruling the agency's interpretation of the standard of proof in asylum determinations ). TABLE OF CONTENTS LEXECUTIVES UMMARY AND INTRODUCTION TO REPORT ......................... 1 n. THE DECISIONS: CONSISTENCY AND RELATED ISSUES ..........................20 m. THE BURDEN OF PROOF......................................................................3 5 A. The Burden of Proof Under International and Domestic Law....................................................................................3. 5 B. The Burden in Practice: Real Facts and Epistemology in the Immigration Court .........................................................3. 8 The Requirement of Conoboration .......................................................... 39 The Requirement of 'Printed Proof and Irrelevancy of Country Condition Evidence............................................................ 41 The Requirement of Direct Visual Observation of Persecutory Events ....................................................................... 47 The Irrelevancy of Subjective Fears and Beliefs .................................................................................... 49 'Paper Hearings ': Limiting O lar Testim ony............................................... 52 IV. THE NON-ADVERSARIAL ADVERSARIAL HEARING ................................54 A. The Role of the Trial Attorney .................................................................5.5 B. The Role of the Immigration Judge ............................................................6 3 C. The Rote of the Lawyer...........................................................................72 V. THE CREDIBILITY DETERMINATION.....................................................7.9 A. Language Interpretation Issues.................................................................7. 9 Common Interpreting Errors ..................................................................... 84 Cred ibiyli t and Interpretation ..................................................................... 88 B. Credibility: Culture and Politics ...............................................................9 2 VI. CONCLUDING COMMENTS.................................................................1 08 CHARTS & GRAPHS Country of Origin of Asylum Applicants (Figure 1).........................................,...... 6A Comparison EOIR and Study Data (Figure 2)....................................................... 7A Factors Cited in Decisions (Figure 3)................................................................ 12A Languages (Figure 4)................................................................................... 12B Interpreter Errors (Figure 4A)......................................................................... 12B Categories of Asylum Claims (Figure 5)............................................................ 13A Relationship of State Department Opinion to Outcome (Figure 6).............................................................................................. 14A Length and Reason for Continuance of Hearing (Figure 7)....................................... 14B Duraoitn of Hearings Chart ...................................................................... 15, m 65 Lawyer Affiliation Chart .......................................................................72, fh 251 Lawyer and Immigration Judge Knowledgeof Asylum Applicant's Language (Figure 8)......................................................... 80A I, I. EXECUTIVE SUMMARY AND INTRODUCTION TO REPORT1 Although several scholars and organizations have issued reports crcitia l of and/or proposing reforms of current asylum procedures,2there has been very little Theprincipalresearcherandauthorof this report is Deborah Anker, Lecturer on Law (Tm- migration Law and Refugee Law), Clinical instructor. Coordinator Immigration Clinical Program s, Har- vard Law School. Dr. Jason Clay, Jay Levy, Dr. Lisa Raphaels, Professor Jennifer Schinner, and Profes- sor Barbara Yngvesson provided invaluable assistance as social science consultants to this project at vari - ous stages in its conception and execution . The author also gratefully acknowledges the following indi- viduals who offered consultation, advice, reviewed earlier drafts, or provided editorial assistance: Profes - sor Alex Alehukoff, Professor Christopher Ediey, Dr. Janet Gilboy, Lucas Guttentag, Arthur Helton, Dan Kesselbreaner, Doris Meissner, Professor Martha Minow, Lory Rosenberg, Dr. Marilyn Tayler and Professor David Trubek. The author w ishoes t express her special gratitude to Professors Gary Bellow and Sally Falk Moore of the Harvard Law School for the inspiration and encouragement which they provided her throughout this project . The following students (including former students) and bilingual observers devoted countless hours of time to research, court observation or assisted in compilation of data; me author learned from them, and to the extent that the study of this court is detailed and thorough it is in large par t attributable to their intelligence, dedication and hard work: Maria Acevedo, Ricardo Anzaldua Montoya, William Brancard, Ted Chiappari , Faith Conant, Thomas Dahdouh, Nicolo Donzella, Jennifer Gordon, Chris Jochnick, Yohannes Kassaben, Barbara Morris , Eileen Morrison , Sarah Paul, Andrew Shaknove, Lorena Sol, Bobbe Steel, Yolanta Strzelecka, David Van Cleve, Gloria Valencia-Weber and Melissa Werger. The author is particularly grateful for the cooperation and ac ceoss t me immigration court studied by immigration judges and staff at mat court aswell as by various other ofcfiaisl at me Executive Oiffce of Immigration Review ("EOlR"). As always, me author is grat efoul t Laurie Corzett as well as Ruth Block and others at the Harvard Law Schoo l Wnor Processing Center, for their skill and sound judgment in assisting in me production of mis report . This study was in part made possible through a grantr fom the Ford Foundation . Whatever is useful and informative in this study is the result of a col- lective effotr . The author remains solely responsible for the content and conclusions. This Part represents a somewhat expanded and in certain mineor rspects modified version of an Executive Summary of this erpo tr released in January of 1990. SeeAnker, 'Determining Asylum Claims in the United States, Summary Report of An Empirical Study of me Adjudication of Asylum Claims be- ofer the Immigration Court ", 2 Intemot'l J. Ref. L.No. 2,252 (1990); see also 11 Refugee Reports 3-7 (Mar. 23,1990), 67 Inter?. ReL 118-120 (1990). Other than information obtained in March of 1990 from a Freedom of Information Act Request described infranote 25 and data described in note 65 infra, data discussed in this erp otr were obtained, compiled and analyzed before the issuance of mat summary. Exceptions , where they e ra relevant , will be noted below. See, e.g.,T. Alexander Alehukoff, "Political Asylum in me Federal Republic of Germany and the Re- public of France: Lessons for me United States", 17 U.Mich.J. Law Ref.183 (1984); Anker and Posner, •The Fyort Year Crisis : A Legislative History of the Refugee Act of 1980", 19 San Diego L.Rev. 9 (1981) (hereinafter "Anker and Posner"); Kurzban, "Restructuring the Asylum Process ", 19 San Diego L.Rev. 91(1981); Martin, "Reforming Asylum Adjudication : On Navigating the Coast of Bohemia", (cid:10)1 138 U.Pa.L.Rev.1247 (1990). empirical investigation of those procedures.3 This study, conducted over a two year period 4, is the first intensive empirical investigation niot the asylum determination pro- cess in the United States. The Refugee Act of 1980: Congressional Mandate for Uniform Asylum Proce- dures, Fairness and Neutrality The Refugee Act of 1980 for the first time created statuto ry asylum procedures for aliens within the United States or at its borders who feared persecution in their home countries and sought U.S. protection .5Congress* major purpose woas t end epr - vious ad hoc treatment of refugees and the use of selection certirai based on foreign policy, country of origin and geographic considerations .6 3For an earlier erp otr on asylum practices in die immigration court and Immigration and Naturalization Service (INS) district in New YoA City,seeFagen, Applying/or Political Asylum in New York Law. Policy and Administrative Practice(1984) (Refugee Policy Group, Washington, D.C.). 4The entire study period was from February 1987 through November 1988. The primary study period extended from February of 1987 through June of 1988. From June of 1988 through November of 1988, researchers attended continued hearings involving cases which previously had been observed. 5Before 1980, me Immigration and Nationality Act ("INA') provided no statutory vehicle o rf persons present in me United States who feared persecution abroad to apply for asylum in this country. The only pre-1980 statutory protection was a discretionary remedy -withholding of deportation-allowing those in deportation proceedings to have return to their home country withheld, based on a persecution claim. See generally.Anker and Posner, supranote 2; Tanfman, 'Political Bias in U.S. Refugee Policy Since me Refugee Act of 1980*, 1 Geo. Immigr. L. J.495 (1986). Asylum protection within me United States, to the extent it was available, was me creature of administrative regulation. The only procedures provided in the INA were o rf those who applied from overseas. The overseas process, however, was available ex- clusively to (hose fleeing rfom communist-dominated countrie s and countries in the Middle East Id. The overseas program often is referred to as a 'refugee'p rogram in contrast to we in-country asylum procedure. See vote 9 infra. 6See Government Accounting ceO iff (GAO) Asylum: Uniform Application of Standards Uncertain—Few Denied Applicants Departed (1987) [hereinafter GAO Asylum Study}at 8; Anker and Posner supranote 2. As noted above, overseas refugee determinations were statutorily limited to thosel feeing cnmmiinisrf-AwninnfArl countries and countries in the Middle East. SeeAnker and Posner supranote 2, Laufmansupranote 5. Under me epr -Refugee Act regulatory asylum scheme, me disparities between the breatment of uwse fleemg communist countries imd mose fleemg countries wiu wmc& me Umted States maintained friendly raeilt ons created a strong perception mat asylum determinations were influenced by foreign policy considerations ; those woo fled from friendly countries , it was argued, faced nearly im- possible odds in obtaining asylum or any protective status. See e.g., Note, 'Behind me Paper Curtain: Asylum Policy Versus Asylum Practice ', 7 N.T .U . Rev. L &Soc. Change 107 (1978). See generally, G. Loescher and J. Scanlon, Calculated Kindness: Refugees and America 's Half Open Door 1945-Present (1986); Zucker and Zucker, The Guarded Gate: The Reality of American Refugee Policy(1987). One of Congress * major purposes in fff»"'*i"gstatutory asylum procedures was to change this perception, and to provide protection within the United States based on the individual merits of persecution claims. See Anker and Posner, supranote 2. In the settlement of a major lawsuit, American Baptist Churches v. Thomburgh,Civ. No. C-85- 3255 RFP (N.D. Cal. Dec. 19, 1990) the government bound i tseolf t the principle mat foreign policy sad border enforcement considerations , along with mae fct (hat an asylum applicant is from a country whose government the United States supports , are not relev anot t me determination of whether the applicant has To bring U.S. law into conformity with international law. Congress adopted a uniform statutory eligibility standard, denning a refugee as an individual with a "well- founded fear of persecution ...on account of race, religion, national origin , membership in a particular social group, or political opinion."7 This definition was taken directly from the governing international treaty , the United Nations Protocol Rela tiong t the Status of Refugees." The new asylum statute established by Congress mandated the creation of proce- dures9which would achieve uniformity, fairness and neutrality in the determinati on of asylum claims. With these new procedures, Congress so ugoht t make asylum proce- dures avai labole t all applicants on a uniform b asois; t ensure that each applicant would have a full oppor tu ynoit t be heard and present his or her claim; aond t ensure that each claim would be evaluated evenhandedly under the neutral international standard adopted by the Act.10 Current Procedures: INS and EOIR To implement the Refugee Act, the Attorney General promulgated regulations establishing two sets of procedures for an alien physically present in the United States ot apply for asylum.11 An applicant who applies proiro t the initiation of deportation "well-founded fear of persecution ." Effectively acknowledging past discrimination against Salvadorans and Guatemalans in the determinaoit n of asylum claims, me government agreed to stop the deportation of most Salvadorans and Guatemalans in the U.S. anod t readjudicate their claims for asylum. See generally 67 Interp. KeL 1480-1485 (1990). See also infranote 57. INA 5101(aX42)(A), 8USC 81101(a)(42XA) (1982). 8Opened o rf signature Jan. 31, 1967,19 U.S.T. 622 (1968). T.LA.S. No. 6577, 606 U.N.T.S. 267. "The Attorney General shall establish a procedure for an alien physically present in the United States or at a land border or port of entry, irrespective of such alien's sta tuos,t apply for asylum, and the alien may be granted asylum in me discretion of me Antto rey General if the Attorney General determines that such alien is a refugee within the meaning of secti on 101 (a)(42XA). • INA §208(a). 8 USC §1158(a) (1982). (emphasis added). Although the grant of asylum is discretionary under me statute, it has been argued mat dsicreti oon t deny asy luom t eligible applicants is li""^ SeeAnker 'Discretio nary Asylum: AProtection Remedy for Refugees under the Refugee Act of 1980,28 Va. J. Int'lL. I (1987); Helton, "The Proper Role of Discretio n in Political Asylum Determinations ', 22 San Diego L. Rev.999 (1988). Discretiontodeny also has been (arcumscribed under adminisb^ve interpretation of the statute. Mo^ ofPulaInt. Dec. 3033 (BIA 1987). For discussion of the mandatory withholding of deportation relief based on a persecution claim, see infranote 11. 10 H.R. Rep. No. 608, 96th Cong., 2d Sees. 18 (1979). 11 After me Refugee Act was enacted,the Attorney General promulgated interim regulations governing these procedures . 45 Fed. Reg. 37392 (1980). Final regualit ons weer promulgated in 1990. 55 Fed. Reg. 30674 (1990). They maintain the division of adjudication between INS and EOIR, but make other changes some of which e ra discussed below. For a general description of those procedures ,seenote 14 infra. In add itioon t asylum, me Refugee Act of 1980 provides a mandatory form of relief rfom deportatio n or return o rf an alien who can prove that his or her "life or freedom would be threatened...on or exclusion proceedings 12files his or her claim with the Immigration and Naturaliza- tion Service ("INS"). An applicant who applies in the course of such proceedings will have his or her claim heard before the Executive Office of Immigration Review ("EOIR")13. The INS procedure (which recently underwent substantial changes) con- sists of an informal, non-recorded interview before an asylum officer who is not re- qu iroed t be an attorney .H account of lace, religion, nationality , membership in a particular social group , or political opinion." INA §243(h), 8 USC §1253(h) (West Supp. 1991). The alien must prove that persecution is "moer likely than not," a less generous standard than that of a "well-founded fear* under the asylum provision which only requires that the alien prove (hat persecution is a 'reasonable possibility.* See INS v. Stevic,467 U.S. 407, 430 (1984); WSv .C ardow-Fonseca,480 U.S. 421, 438-439 (1987). Withholding of deportation or return only protects against re turno t the country of persecution and provide s no status in the United States. A grant of asylum can leoad t permanent residency status. I.N.A. §209(b), 8 USC §1159(b) (West Supp. 1991). 12 These era proceedings initiated by me governm eont t seek the aliene's rmoval from me United States. See generally T. Aleinikoffand D. Martin, Immigration Process and Policy (1985) (hereinafter T. Aleinikoff and D. Martin Immigration) at 19-20. An updated revision of this text will be available in September 1991. 13 By regulation in 1983, me EOIR was created as a separate agency from me INS P rioor t mat time , me immigration judges weer part of me INS The purpose of me separation woas t remove any perception of prosecutorial bias fomr me performance of the adjudicatory function of the immigration court. SeeT. Aleinikoff and D. Martin Immigration supranote 12 at 89. For a detailed discussion of me mechanics of mese procedures feeJd. at 638-643; Anker et al. The Law of Asylum in the United Statesat 15-26 (Americim Immigratio n Lawyers Association 1989) (hereinafter "Anker et al. U.S. Asylum Law').A revision of mis text will be available in June 1991. 14 See generally Anker et al. U.S. Asylum Law supranote 13 at 15-20 and T. Aleinikoff and D. Martin Immigration supranote 12 at 642-643. Seenote 11 supra.The regulations promulgated on July 27,1990 (after the completion of mis study) create a new corps of asylum offi ceors t adjudicate claims m aode t the INS. The asylum officers era directly respons ibleo t the Office of Refugees, Asylum and Parole of me INS ("CORAP') and noot t me local INS District Dreicotr s. Their only function wi ll obe t adjudicate asylum claims, and they will receive specialized training and supervision. In addition , a specialized documentation center will be maintained orf me collection and dissemination of information on human rights conditions . See8 CFR §§208.1,208.12(1990). There era a number of other important changes made by me 1990 regulations some of which re- laote t evidence and procedure , o thoers t substantive interpretations of me definition . For example, me asylum officer may make a decision without receiving a response from me State Department's Bureau of Human Rights and Humanitarian Aaffirs ("BHRHA") 8 CFR §208.11 (o fr e orl of me State Department generally, seenote 17 infra), the asylum officer is specifically instructed mat he or she may consider material provided by credible sources other than the State Department (such as international organiza- tions , private voluntary agencies, or academic institutions ) 8 CFR §208.12; me credibility of the ap- plicant's testimon y ois t be evaluated in light of general conditions in his or her country 8 CFR §208.13; the applicant need not establish that he or she would be singled out for persecution if he or she can estab- lish that meer is a pattern or practice of persecution of the group of persons similarly situated, etc. Id. Itshould be noted mat several of these provisions only specifically bind the INS Asylum Of- ficers , not the EOIR immigration judges. 4 The EOIR procedure is a formal administrative hearing presided over by an im- migration judge, who is an attorney . The immigration judge is empow eroed t examine the alien and any other witnesses presented.15In the EOIR procedure, there are only general standards and no specific rules governing the admission of evidence; any evi- dence the applicant presents is admissible under a broad criterion of relevance.16The immigration judge also evaluates evidence and issues decisions. The statute requires that those decisions be based on record evidence. hi both processes, the regulations require the adjudic atoor t request an advisory opinion from the State Department's Bureau of Human Rights and Humanitarian Af- fairs ("BHRHA") before rendering a final decision on the merits of (he asylum claim, and that opinion is made part of the record.17 In the EOIR procedure, the applicant has the righot t be represented by counsel at no exp enose t the governm enot, t present witnesses and other evidence aond t cross-examine adverse witnesses.18 The govern- ment is also represented by counsel.19 15 See generally Ankeretal. U.S. Asylum Law supranote 13 at 20-21 and T. Aleinikoff and D. Marnit Immigration supra neot 12 at 643. 16 8 R TC §242.14(c) (1990). "The specialinquiry ceri off [immigrationj udge] may receive in evidence any oral or written statement wmch is material and releva mo t any issue in the case previously made by the respondent [alien] or any other person during any investigation , examination, hearing , or trial . * The immigration court is not bound by the Federal Rules of Civil Procedure or the Federal Rules of Evi- dence. la 1988, the ceO iff of the Chief Immigration Judge prom ulgated final reol s governing procedur es in immigration court . 8 CFR §§3.12-3.38. These are generally rudimentary. For example, as discussed mf ait TV infra, there are no rig htos t nor procedures governing discovery. Commenting generally about immigration court proceedings, practitioners have noted the 'ab- sence of any written rules of procedures that would set out..rig htso t discovery or set me regular stan- dard for litigation .... Because there are no formal procedures , you are left doing things informally.'' Girdner, "Inside the Immigration Court ", California LawyerJune 1986 at p.63. See alsoT. Aleinikoff and D. Martin Immigration supranote 12 at 422 and Anker et al. 17.5. Asylum Law supranote 13 at 54. 17 See former 8 CFR §§208.7, 208.10(b) (1990) (in effect at tmi e of study). See generally Anker et al. U.S. Asylum Lawat 16,19. For changes under the new asylum regulations , seenote 14 supra. The new regulations clearly state that me asylum ceoirf f or immigration judge may render a decision without receiving a BHRHA opinion if at least 60 days have elapsed since the request for the opinion. 8 CFR §208.11 (1990). 18 INA §242(B)(aXlXE), 8 USC }1252(b)(a)(lXE) (West Simp. 1991), INA §292, 8 USC §1362 (1982) (r ighot t counsel); former INA §242(b)(3), 8 USC }1252(b)(3) (1982) ( righot tpresent evidence, cross examine witnesses and ob jeoct t adverse witnesses). This specific provisio n s eemos t have been removed ac part of a recent extensive revision of the immigration statute. SeeImmigration Act of 1990, Pub.L. 101-649, 104 Stat. 4978 (hereinafter "IMACT 90"). It is unclear whether the removal was pur- poseful or may be corrected through a technical corrections act. These specific rights also may beo rp - vided for by regulation. SeeINA §242(b), 8 USC §1252(b) (West Supp. 1991) (providing o rf the is- suance of regulations governing me conduct of deportation proceedings ). 19 See, e.g.T. Aleinikoff and D. Martin Immigration supranote 12 at 413, citing Wassennan, "Practi- cal Aspects of Representing An Alien at a Deportati on Hearing ", 14 San Diego L.Rev. 111(1976). The EOIR proceedings are recorded,20and the alien has the righot t a decision based on the record. Both the government and the alien can appeal a decision to the Board of Immigration Appeals ("BIA" or "Board"), an administrative appellate unit within the EOIR. The alien can further ap peoal t the federal diistrct or circuit court of appeals.21 Research Design The data in this study were obtained by bilingual and other researchers in the course of observing EOIR asylum hearings .2* Interviews also were conducted with hearing participants and government officials.23In total , observers attended 193 hear- ings, comprising 149 cases of asylum claims of applicants from 31 different coun- tries .24This represents a proportional and representative selection of the immigration court which comprised the study sample. The accuracy of the statistical data collected has been generally confirmed ,o25t the extent it was provided by and available from the 20 Therecordof the proceeding is maintained by a tape recording ; the re<»rdinginediani^ led by the immigration judge. T. Aleinikoff and D. Martin Immigration supranote 12 at 411. 21 T. Aleinikoff and D. Martni Immigration supranote 12 at 643; Anker et al. U.S. Asylum Lawat 26. 22 Researchers included a law instructor, anthropologists, law students and observers bilingual in English and Amharic , Arabic, Creole , Polish and Spanish. See supranote 1. Observers were eat med by the principal investigator and social science consultants. Detailed notes were maintained on hearings with observers taking notes on all transactions in the courtroom in- cluding, orf example, both those mat were officially recorded as well as comments and exchanges made 'off me cer ord* (i.e. when me cer ording devise was shut on; see supranote 20). In many cases, ob- servers arrived early or remained after (he hearings were completed during which tmi e they interviewed participants. Interviews with participant s also were conducted at other tmi e s. Data also were maintained for each hearing through standardize data sheets, developed in consultation with me social science con- sultants. All data from hearing observations-quantitative and qualitative—were collated through a data base program developed specifically for this study. Fifty fields were included in me data base. 23 As indicated,interviews were conducted with hearing participants , with some immigration judges in other parts of me country as well as with various other EOIR ocffiaisl . 24 See Fgiure 1. 25 As indicated,me data for this study initially were obtained through extensive observation, monitor- ing and interviewing in me immigration court studied. A Freedom Of Information Act Request (FOIA) also was filed , and a response to that request was obtained on March 6, 1990. According to mat in- formation , EOIR generally does not isolate data on the particular city studied, but maintainscomposite data on mat city along with two smaller cities as well as other co urots t which the particular immigration judges were detailed. (Together these era designated me 'Base City.') (Some information provided in the FOIA may have rela tedo t the particular citystudied in this report . However, me informati on was ambiguous and could not be clarified with complete confidence after a conversation with the EOlR's General Counsel on April 2, 1991. Since me information is unclear, it is not being used.) Accor dinog t EOlR's information, 474 asylum applications were received in the enrei t 'base city" during the study period ; me study included 149 applications (cases) in one city for the period in which initial hearings were observed (February 1987 through June 1988). Seenote 1, supra. Although the data base rfom me EOIR and me study era different , the FOIA information indi- cates that the study sample was representatvie with resp ecto t most important nationali ty groups . For ex- (Figure 1) COUNTRY OF ORIGIN OF ASYLUM APPLICANTS (BY CASES) Afghanistan 2 Bolivia 2 Chile 1 China 4 Colombia 1 Cuba 1 Dominican Republic 2 HSalvador 47 Ethiopia 10 Ghana 2 Greece 1 Guatemala 11 Haiti 12 Honduras 1 Hungary 1 India 2 Iran 9 Israel 1 Ivory Coast 1 Lebanon 3 Liberia 5 Libya 1 Nicaragua 3 Nigeria 2 Peru 1 Poland 4 Somalia 1 iSr Lanka 8 Taiwan 1 Vietnam 1 Zimbabwe 1 Unknown 7 — — — — — — — — — — — — — — — "Total—31— 149 Total countries cases