APR302018_01B4203Decided 2018-04-30I-140

A South African food export company's EB-1C petition for its beneficiary as an international expansion coordinator was…

Dismissed Useful for: avoid these mistakes
EB-1CField: South African food exporter engaged in manufacture and distribution of diverse South African food products including specialty sauces, drinks, and high-end chocolatesOrigin: South Africa
The outcome

This appeal was not successful at this stage

The AAO denied the motion to reconsider and granted the motion to reopen only in part to consider the previously omitted brief, but ultimately upheld the denial because the petitioner failed to establish that the beneficiary would be employed in a managerial capacity in the U.S. and had not shown qualifying managerial or executive employment abroad for the required one-year period.

In plain English

The AAO reviewed a combined motion to reopen and reconsider an EB-1C petition filed by a South African food exporter seeking to employ a beneficiary as a 'Market Manager (International Expansion Coordinator).' The motion to reopen was partially granted to consider a brief that had been timely submitted but not included in the record. On de novo review, the AAO upheld the denial because the petitioner's duty descriptions were vague and conclusory, the record showed the beneficiary was involved in numerous non-qualifying operational tasks, and conflicting IRS filings and inconsistent organizational charts left material questions about whether sufficient staff existed to relieve the beneficiary from operational duties at the time of filing. The AAO also declined to address the foreign employment issue in depth, finding the U.S. employment deficiency alone dispositive.

What worked & what failed

What failed: 1. Duty descriptions for the proposed managerial role were too vague and conclusory, lacking day-to-day specifics needed to show the role was primarily managerial. 2. Conflicting IRS payroll records and inconsistent organizational charts undermined claims about staffing levels, making it impossible to show the beneficiary would be relieved of operational tasks. 3. Documentary evidence (purchase orders, invoices, FDA agent role) affirmatively showed the beneficiary was performing non-qualifying operational work, and the petitioner never quantified the managerial vs. operational split.

Takeaway: For EB-1C petitions, petitioners must provide granular, concrete evidence of both the beneficiary's managerial duties and the supporting staff structure with corroborating payroll records, W-2s, and detailed subordinate duty descriptions — vague organizational charts and conclusory duty letters are insufficient, especially when other evidence reveals operational involvement.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-1C criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • Duty descriptions for the proposed managerial role were too vague and conclusory, lacking day-to-day specifics needed to show the role was primarily managerial
  • Conflicting IRS payroll records and inconsistent organizational charts undermined claims about staffing levels, making it impossible to show the beneficiary would be relieved of operational tasks
  • Documentary evidence (purchase orders, invoices, FDA agent role) affirmatively showed the beneficiary was performing non-qualifying operational work, and the petitioner never quantified the managerial vs
Find more EB-1C cases with similar evidence patterns →
Evidence that persuaded the AAO

Proof that the petitioner's brief was timely mailed to the Texas Service Center within 30 days of filing the appeal, supporting partial grant of the motion to reopen.

Where the evidence fell short

Vague and conclusory duty descriptions for the beneficiary's proposed Market Manager (International Expansion Coordinator) role without day-to-day specifics

Conflicting IRS Form 941 Employer's Quarterly Federal Tax Returns from Q1 2010 showing inconsistent employee counts and wage figures

Organizational charts that were inconsistent across filings and not corroborated by payroll records, W-2s, or 1099s from 2009-2010

Employment offer letters showing the operations manager and staff accountant did not join until August 2012, contradicting earlier organizational charts

Purchase orders, invoices, and transactional documents bearing the beneficiary's name indicating involvement in non-qualifying operational tasks

Broad assertions that the beneficiary would manage an essential function without clearly defining the function or documenting delegation of operational duties

Officer errors the AAO found

The AAO's prior summary dismissal of the appeal was correct on the record at the time, but the brief had not been included in the record due to a processing delay — not a legal error by the Director but a procedural gap corrected on motion to reopen.

The Director's finding on qualifying foreign employment was upheld as the petitioner failed to submit required duty lists and subordinate evidence.

How the case moved

Completed

I-140 filed

International expansion coordinator / market manager for a food export company

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2018-04-30

AAO decision — Dismissed

The AAO denied the motion to reconsider and granted the motion to reopen only in part to consider the previously omitted brief, but ultimately upheld the denial because the petitioner failed to establish that the beneficiary would be employed in a managerial capacity in the U.S. and had not shown qualifying managerial or executive employment abroad for the required one-year period.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

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Authorities the office relied on
8 C.F.R. § 103.5(a)(2)8 C.F.R. § 103.5(a)(3)8 C.F.R. § 103.2(b)(1)8 C.F.R. § 204.5(j)(3)8 C.F.R. § 204.5(j)(5)8 C.F.R. § 214.2(l)(1)(ii)(B)(1)
Champion WorldThe petitioner must show the beneficiary will perform high-level responsibilities consistent with the statutory definition of managerial capacity and will be primarily engaged in managerial rather than operational duties.
Family Inc.The beneficiary must be primarily engaged in managerial duties as opposed to ordinary operational activities alongside other employees.
Fedin Bros.Conclusory assertions and mere repetition of statutory language do not satisfy the petitioner's burden of proof.
Avyr AssociatesMerely repeating the language of the statute or regulations does not satisfy the petitioner's burden of proof.
IKEA U.S.Without clear information on the proportion of qualifying versus non-qualifying duties, it cannot be determined whether the beneficiary is primarily performing executive or managerial duties.
Matter of Church Scientology Int'lAn employee who primarily performs tasks necessary to produce a product or provide services is not considered to be primarily employed in a managerial or executive capacity.
Matter of HoDiscrepancies in the record must be resolved with independent, objective evidence pointing to where the truth lies.
Matter of G- Inc.Sets out the five-part test for function manager status: clearly defined activity, essential/core to the organization, beneficiary primarily manages rather than performs the function, acts at senior level, and exercises discretion over day-to-day operations of the function.