FEB272017_04D2101Decided 2017-02-27I-129

A software consulting company's H-1B petition for a Hadoop engineer was dismissed because it could not prove it…

Dismissed Useful for: avoid these mistakes
H-1BField: Software development and consulting; Hadoop engineer/tester; Big Data systems
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to establish both a valid employer-employee relationship with the beneficiary and that the proffered position qualifies as a specialty occupation.

In plain English

The AAO dismissed this H-1B appeal filed by a Colorado-based software development company seeking to employ a Hadoop engineer/tester who was actually working at a California end-client's site through a chain of intermediary vendors. The AAO found that the petitioner failed to establish a valid employer-employee relationship because documentary evidence — including the beneficiary's badge, system access records, and a purchase order — consistently identified the beneficiary as a contractor of an intermediary company, not the petitioner, and the end-client directed the beneficiary's work. The AAO also found the specialty occupation prong unmet because the job duties were described too vaguely to assess their complexity or specialization, the end-client confirmed only that specialized knowledge was needed but made no statement about a degree requirement, and an expert opinion letter was discounted because it lacked grounding in the actual work performed. The petitioner's own tax return, which showed no employee wages paid, further undermined its claim of an employer-employee relationship.

What worked & what failed

What failed: 1. The petitioner could not show it actually controlled the beneficiary's work — the end-client and an intermediary vendor directed the beneficiary's daily activities, not the petitioner. 2. Job duty descriptions were too vague and generic to demonstrate the position required a specific specialized degree, defeating the specialty occupation claim. 3. An expert opinion letter was given little weight because the expert had no firsthand knowledge of the actual work, the end-client, or its projects, and did not address the entry-level wage designation on the labor condition application.

Takeaway: In third-party placement H-1B cases, petitioners must provide detailed, consistent evidence of actual supervision and control over the beneficiary's daily work — not just assertions — and must obtain explicit statements from the end-client confirming both the degree requirement and the petitioner's role as employer. Vague job duty descriptions and expert opinions untethered to the specific worksite and project will not establish specialty occupation.

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 H-1B criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The petitioner could not show it actually controlled the beneficiary's work — the end-client and an intermediary vendor directed the beneficiary's daily activities, not the petitioner
  • Job duty descriptions were too vague and generic to demonstrate the position required a specific specialized degree, defeating the specialty occupation claim
  • An expert opinion letter was given little weight because the expert had no firsthand knowledge of the actual work, the end-client, or its projects, and did not address the entry-level wage designation on the labor condition application.
Find more H-1B cases with similar evidence patterns →
Evidence that persuaded the AAO

Beneficiary's identification badge, organization profile page, and system access page issued by end-client showing beneficiary is a contractor of Company R

Purchase order between end-client and Company R naming Company R as supplier of beneficiary's services

End-client email confirming that beneficiary should seek employment verification from Company R, not petitioner

Petitioner's 2014 tax return showing no employee salaries/wages paid but $250,302 in contract labor deductions

Where the evidence fell short

Vendor letters from Company I and Company R asserting petitioner supervises beneficiary — contradicted by documentary evidence

Subcontractor agreement and work order with Company I — inconsistent as to which company is the end-client's direct vendor

Petitioner's assertions that it manages and supervises beneficiary remotely from Colorado — unsupported by concrete evidence of communication or oversight

Expert opinion letter from professor at School of Management — not based on actual knowledge of end-client, end-client project, or beneficiary's work products, and did not address Level I wage designation

End-client email confirming in-depth knowledge of Hadoop required — silent on degree requirement for the position

Brief list of job duties — insufficient detail on complexity, specialization, or difficulty to establish specialty occupation

How the case moved

Completed

I-129 filed

Hadoop engineer and tester working with Big Data systems, including Hadoop ecosystem components such as Hive, Pig, Sqoop, and Flume

Completed

California Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2017-02-27

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to establish both a valid employer-employee relationship with the beneficiary and that the proffered position qualifies as a specialty occupation.

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(h)(4)(ii)8 C.F.R. § 214.2(h)(4)(iii)(A)8 C.F.R. § 214.2(h)(1)8 C.F.R. § 214.2(h)(2)(i)(A)
DardenWhere federal law fails to define 'employee,' courts apply the conventional master-servant relationship under common-law agency doctrine; lists factors for determining employment status.
ReidCited within Darden for the proposition that undefined 'employee' should be interpreted under common-law agency doctrine.
ClackamasThe key common-law touchstone for determining employer-employee relationship is control; no single factor is decisive.
DefensorWhere work is performed for third-party clients, evidence of client companies' job requirements is critical to establishing specialty occupation; the entity directing the work may be the 'true employer.'
Royal SiamA degree requirement for specialty occupation must relate directly to the duties and responsibilities of the particular position.
ChevronA federal agency's interpretation of a statute it administers is entitled to deference unless Congress has spoken directly on the issue.
AuerAn agency's interpretation of its own ambiguous regulation is controlling unless plainly erroneous or inconsistent with the regulation.
BowersCourts generally refuse to extend common-law agency definition to ERISA's use of 'employer' because ERISA's definition of employer shows legislative intent to extend beyond traditional common law.
NLRB v. United Ins.All incidents of the relationship must be assessed and weighed; no one factor is decisive in the employment determination.
Matter of HoIt is incumbent upon the petitioner to resolve inconsistencies in the record; unsubstantiated explanations will not suffice.
ChawathePetitioner must support assertions with relevant, probative, and credible evidence.
Caron Int'lUSCIS may use expert opinion statements as advisory but is not required to accept opinions that are not in accord with other information or are questionable.