FEB202024_02B2203Decided 2024-02-20I-140

An EB-1A petition filed by a clinical psychologist and researcher was dismissed because the Form I-140 bore an invalid…

Dismissed Useful for: avoid these mistakes
EB-1AField: clinical psychologist and researcher
The outcome

This appeal was not successful at this stage

The appeal was dismissed on two independent grounds: (1) the Form I-140 bore a word-processor-generated signature rather than a valid handwritten or authorized electronic signature, rendering the petition improperly filed; and (2) the petitioner failed to demonstrate satisfaction of at least three of the ten evidentiary criteria, meeting only two (judging and scholarly articles) rather than the required minimum of three.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

A clinical psychologist and researcher in New York sought EB-1A extraordinary ability classification. The AAO dismissed the appeal on two independent grounds. First, the Form I-140 was signed using a word processor rather than a valid handwritten or electronically authorized signature, rendering the petition improperly filed under USCIS policy. Second, on the merits, the petitioner satisfied only two of the required three criteria (judging and scholarly articles); his high-salary claim failed because his $166,161 income fell below the 90th-percentile OEWS benchmark of $168,790, and the supplementary salary surveys from Indeed and ZipRecruiter were either based on too small a sample or showed higher figures than his own earnings. Because the minimum evidentiary threshold was not cleared, no final merits determination was conducted.

What worked & what failed

What failed: 1. The Form I-140 signature was generated by a word processor rather than being personally handwritten, which alone was sufficient to dismiss the petition. 2. Salary evidence failed because the petitioner's income fell below the BLS 90th-percentile figure, the Indeed survey had only 77 reported salaries, and ZipRecruiter showed higher 'top earner' figures than the petitioner's salary — none of the sources provided a sufficiently tailored geographic or role-specific comparison. 3. The petitioner could only demonstrate two qualifying criteria (judging and scholarly articles), one short of the required three.

Takeaway: Ensure the Form I-140 bears a valid handwritten or properly authorized electronic signature before filing, as a deficient signature alone will doom the petition. When claiming the high-salary criterion, submit position-specific and geographically appropriate compensation surveys with robust sample sizes rather than relying on general national statistics or crowdsourced salary websites with small respondent pools.

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

  • See summary above for details.

Evidence that wasn't enough alone

  • The Form I-140 signature was generated by a word processor rather than being personally handwritten, which alone was sufficient to dismiss the petition
  • Salary evidence failed because the petitioner's income fell below the BLS 90th-percentile figure, the Indeed survey had only 77 reported salaries, and ZipRecruiter showed higher 'top earner' figures than the petitioner's salary — none of the sources provided a sufficiently tailored geographic or role-specific comparison
  • The petitioner could only demonstrate two qualifying criteria (judging and scholarly articles), one short of the required three.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Judging the work of others

Met

Director found this criterion met; AAO did not disturb that finding.

Authorship of scholarly articles

Met

Director found this criterion met; AAO did not disturb that finding.

High salary or other significantly high remuneration

Not met

Petitioner's 2022 income of $166,161 fell below the OEWS 90th-percentile figure of $168,790; Indeed data had only 77 reported salaries (insufficient sample); ZipRecruiter showed top earners of $158,054 with salaries as high as $181,115, exceeding petitioner's salary; none of the sources provided geographically or position-appropriate comparisons for a clinical psychologist/researcher in New York.

Evidence that persuaded the AAO

Evidence of participation as a judge of the work of others in the field (criterion iv) — accepted by the Director and undisturbed on appeal

Authorship of scholarly articles (criterion vi) — accepted by the Director and undisturbed on appeal

Where the evidence fell short

2022 Form W-2 showing income of $166,161 — fell below the OEWS 90th-percentile benchmark of $168,790

BLS Occupational Employment and Wage Statistics (OEWS) data — nationwide, all-settings survey not sufficiently tailored to petitioner's geographic location or research role

Indeed salary data — only 77 reported salaries, sample size deemed too small to be reliable

ZipRecruiter salary data — showed top earners of $158,054 and salaries as high as $181,115 (higher than petitioner); scope and settings not adequately defined

Form I-140 signature — created by word processor; deemed a deficient signature under USCIS policy, rendering the petition improperly filed

How the case moved

Completed

I-140 filed

Clinical psychologist and researcher based in New York

Completed

Nebraska Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2024-02-20

AAO decision — Dismissed

The appeal was dismissed on two independent grounds: (1) the Form I-140 bore a word-processor-generated signature rather than a valid handwritten or authorized electronic signature, rendering the petition improperly filed; and (2) the petitioner failed to demonstrate satisfaction of at least three of the ten evidentiary criteria, meeting only two (judging and scholarly articles) rather than the required minimum of three.

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. § 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)(iv)8 C.F.R. § 204.5(h)(3)(vi)8 C.F.R. § 204.5(h)(3)(ix)8 C.F.R. § 103.2(a)(2)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 whether minimum criteria are met, then conduct a final merits determination of sustained acclaim.
VisinscaiaExtraordinary ability designation is extremely restrictive by design.
ValdezA person's signature on an immigration form creates a strong presumption that the signer knows and assented to its contents.
ThompsonCited for the presumption that a signatory knows and assents to a form's contents.
BinghamCited for the presumption that a signatory knows and assents to a form's contents.
RiveraWithout the declarant's actual personal signature, a declaration under penalty of perjury has no evidentiary force.
PriceHigh salary must be evaluated against comparators in the same field; even major-league athletes do not automatically meet the extraordinary ability standard.
GrimsonHigh salary criterion requires comparison to salaries of similarly situated individuals in the same role.
MuniHigh salary criterion requires comparison to salaries of similarly situated individuals in the same role.
Hamal IIEB-1 visas are reserved for a very small percentage of prospective immigrants.
Hamal IEven highly accomplished individuals may fail to meet the extraordinary ability designation.