FEB062024_01B2203Decided 2024-02-06I-140

The AAO remanded an EB-1A denial for a management information systems professor, finding she met three criteria…

Remanded Useful for: appeal strategy
EB-1AField: management information systems
The outcome

Good news — this case cleared the first bar

The AAO withdrew the Director's denial and remanded for a new decision, finding that the Petitioner met three of the required criteria (published material, judging, and scholarly articles) and that the Director had improperly imposed a novel evidentiary requirement in evaluating the published material criterion.

3 / 3 criteria needed Threshold cleared ✓

Next step: a full merits review weighing all the evidence together.

In plain English

A tenure-track assistant professor in management information systems appealed the denial of her EB-1A petition after the Nebraska Service Center found she met only two of the required three evidentiary criteria. The AAO found that the Director had improperly imposed a novel requirement for the published material criterion, demanding that coverage focus on the petitioner's broader accomplishments rather than simply being about her and her work. The AAO reversed the Director on that criterion, finding that coverage in major technology publications and NPR satisfied the plain regulatory standard. Because the petitioner now met three criteria (published material, judging, and scholarly articles), the AAO withdrew the denial and remanded for a final merits determination. The case is a reminder that adjudicators cannot add requirements beyond what the regulations and USCIS policy explicitly state.

What worked & what failed

What worked: Coverage in major technology publications and NPR discussing the petitioner's research was sufficient to satisfy the published material criterion under the plain regulatory language. Evidence of peer review judging and authorship of scholarly articles were uncontested and clearly met.

What failed: The petitioner's evidence of original contributions of major significance (criterion v) was not found sufficient by either the Director or the AAO, and that issue was left open for the Director to reconsider on remand.

Takeaway: When challenging a denial on appeal, carefully identify whether the officer applied standards beyond those in the regulations or USCIS policy manual — the AAO will reverse novel or extra-regulatory requirements. Make sure published media coverage is clearly about the petitioner and their work, even if it also discusses broader research topics.

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-1A criteria.

Evidence that moved the needle

  • Coverage in major technology publications and NPR discussing the petitioner's research was sufficient to satisfy the published material criterion under the plain regulatory language
  • Evidence of peer review judging and authorship of scholarly articles were uncontested and clearly met.

Evidence that wasn't enough alone

  • The petitioner's evidence of original contributions of major significance (criterion v) was not found sufficient by either the Director or the AAO, and that issue was left open for the Director to reconsider on remand.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Published material about the person

Reversed in their favor

Director denied this criterion by requiring published material to focus on the petitioner's accomplishments in the wider field, not merely research results. AAO found this was a novel requirement not found in the regulation or USCIS policy manual, and concluded that articles in major tech publications (W- and G-) and NPR satisfied the criterion.

Judging the work of others

Met

Director found this criterion met; AAO affirmed.

Original contributions of major significance

Not met

Director denied this criterion; Petitioner appealed but AAO did not reverse it, instead remanding for further review.

Authorship of scholarly articles

Met

Director found this criterion met; AAO affirmed.

Evidence that persuaded the AAO

Interviews and articles in major technology publications (identified as W- and G-) discussing the Petitioner's work

Coverage on National Public Radio (NPR) relating to the Petitioner's research

Evidence of participation as a judge of others' work in the field

Authorship of scholarly articles in the field of management information systems

Where the evidence fell short

Evidence submitted for the original contributions of major significance criterion (8 C.F.R. § 204.5(h)(3)(v)) was found insufficient by the Director, and the AAO did not reverse that finding on appeal

Officer errors the AAO found

Director imposed a novel substantive requirement for the published material criterion (8 C.F.R. § 204.5(h)(3)(iii)) by requiring that material focus on the petitioner's accomplishments in the wider field, rather than simply being about the person relating to their work, which is not supported by the plain language of the regulation or USCIS policy.

How the case moved

Completed

I-140 filed

Tenure-track assistant professor and researcher studying the impact of online platforms' technology policies on businesses and society

Completed

Nebraska Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2024-02-06

AAO decision — Remanded

The AAO withdrew the Director's denial and remanded for a new decision, finding that the Petitioner met three of the required criteria (published material, judging, and scholarly articles) and that the Director had improperly imposed a novel evidentiary requirement in evaluating the published material 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.

Find this useful? A coffee helps keep Case Reviewer free and ad-free.

Buy me a coffee
Authorities the office relied on
8 C.F.R. § 204.5(h)(2)8 C.F.R. § 204.5(h)(3)8 C.F.R. § 204.5(h)(3)(i)-(x)8 C.F.R. § 204.5(h)(3)(iii)8 C.F.R. § 204.5(h)(3)(iv)8 C.F.R. § 204.5(h)(3)(v)8 C.F.R. § 204.5(h)(3)(vi)8 C.F.R. § 103.3
ChawathePetitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence.
Christo'sAAO reviews questions de novo.
KazarianEstablishes the two-step review framework: first count qualifying criteria, then conduct a final merits determination; also prohibits USCIS from utilizing novel substantive or evidentiary requirements beyond those in the regulations.
VisinscaiaSupports the Kazarian two-part review framework for extraordinary ability cases.
RijalSupports the Kazarian two-part review framework for extraordinary ability cases.