DEC072022_01D8101Decided 2022-12-07I-129

A restaurant and catering company's O-1 petition for a culinary director was dismissed after the petitioner failed to…

Dismissed Useful for: avoid these mistakes
O-1BField: culinary arts / culinary director for a restaurant and catering business
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to establish that the beneficiary met at least three of the six regulatory criteria required for O-1 extraordinary ability in the arts. The AAO also reversed the Director's favorable finding on the high salary criterion.

0 / 3 criteria needed Need 3 more

3 more criteria would trigger a full merits review.

In plain English

The petitioner, a restaurant and catering business, sought O-1B classification for a beneficiary it wanted to employ as a culinary director. The Vermont Service Center denied the petition, finding only one of six required criteria met (high salary). On appeal, the AAO reviewed all contested criteria de novo and found none satisfied: event flyers and festival materials failed to establish distinguished reputations, media coverage was from publications too small or local to confer national or international recognition, and the high salary comparison used data for chefs and head cooks rather than culinary directors. The AAO reversed the Director's favorable high salary finding and dismissed the appeal. Because fewer than three criteria were met, no totality-of-the-evidence analysis was conducted.

What worked & what failed

What failed: 1. Published materials criterion failed because the submitted articles were either about a different person, illegible, or from local/regional publications without sufficient reach to confer national or international recognition. 2. Lead or starring participant criterion failed because event flyers and festival materials did not establish the distinguished reputation of the events, and future wedding catering contracts did not mention the beneficiary or prove event prestige. 3. High salary criterion failed because the petitioner compared the beneficiary's salary to chefs and head cooks rather than to other culinary directors, who hold different responsibilities.

Takeaway: Petitioners must use occupation-specific wage comparisons — not broader or related job titles — when asserting a high salary, and must submit independent, objective evidence (such as third-party reviews or circulation data from reliable sources) to establish both the prominence of the publications covering the beneficiary and the distinguished reputation of events where the beneficiary performed.

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 O-1B criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • Published materials criterion failed because the submitted articles were either about a different person, illegible, or from local/regional publications without sufficient reach to confer national or international recognition
  • Lead or starring participant criterion failed because event flyers and festival materials did not establish the distinguished reputation of the events, and future wedding catering contracts did not mention the beneficiary or prove event prestige
  • High salary criterion failed because the petitioner compared the beneficiary's salary to chefs and head cooks rather than to other culinary directors, who hold different responsibilities.
Find more O-1B cases with similar evidence patterns →
Where the evidence fell short

Event flyers that did not mention the beneficiary or establish distinguished reputation of the events

Articles from Daily Post India and Yugmarg that were not legible

Article from The Hindu that covered a different individual with the same name as the beneficiary

Local and regional publication articles that lacked the reach to confer national or international recognition

Circulation data sourced from Wikipedia, which lacks reliability assurances

New York Times article about the petitioning company that did not mention the beneficiary

Catering contracts for wedding events that did not name the beneficiary or establish the distinguished reputation of the events

Wage data from FLCDC and USBLS for 'Chefs and Head Cooks' rather than culinary directors

Food critic letter that praised the beneficiary's dish but did not address the reputation or standing of the festival

Comparable evidence argument raised for the first time on appeal and not presented to the Director

Officer errors the AAO found

Director incorrectly found the high salary criterion met because the petitioner compared the beneficiary's salary to chefs and head cooks rather than to other culinary directors, who have different responsibilities and duties

Director's favorable finding on high salary was based on inapt occupational comparison data

How the case moved

Completed

I-129 filed

Culinary director overseeing food preparation, menu creation, and kitchen staff for restaurants and catering events

Completed

Vermont Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2022-12-07

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to establish that the beneficiary met at least three of the six regulatory criteria required for O-1 extraordinary ability in the arts. The AAO also reversed the Director's favorable finding on the high salary criterion.

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. § 214.2(o)(3)(ii)8 C.F.R. § 214.2(o)(3)(iv)8 C.F.R. § 214.2(o)(3)(iv)(A)8 C.F.R. § 214.2(o)(3)(iv)(B)8 C.F.R. § 214.2(o)(3)(iv)(B)(1)8 C.F.R. § 214.2(o)(3)(iv)(B)(2)8 C.F.R. § 214.2(o)(3)(iv)(B)(3)8 C.F.R. § 214.2(o)(3)(iv)(B)(5)8 C.F.R. § 214.2(o)(3)(iv)(B)(6)8 C.F.R. § 214.2(o)(3)(iv)(C)
ChawatheTruth is determined not by the quantity of evidence alone but by its quality
SorianoEvidence not presented to the Director before denial will not be considered on appeal; the appeal is adjudicated on the record before the Director
ObaigbenaSupporting authority for limiting appellate record to evidence presented before the Director
P. SinghA reviewing tribunal may adopt and affirm a lower decision where facts and evaluative judgments have been adequately confronted and correctly resolved
BurbanoAdoption and affirmance of lower tribunal findings on appeal
ChenA reviewing tribunal may adopt lower findings when facts and evaluations were adequately confronted and correctly resolved
Braga v. PoulosSelf-serving assertions on a publication's cover about its own status are not reliable evidence of major medium standing
Badasa v. MukaseyWikipedia is an open, user-edited site without reliability assurances and should not be given weight
Matter of PriceHigh salary criterion requires comparison to others in the same specific occupation, not a broader or different one
SkokosSalary information for those performing lesser duties is not a proper comparison to others in the field
Crimson v. INSSalary comparison must be made against peers in the same specific role
Muni v. INSSalary comparison must be made against peers in the same specific position
BagamasbadFederal agencies are not required to make findings on issues unnecessary to the result reached
Matter of L-A-C-Alternative issues on appeal need not be reached where an applicant is otherwise ineligible