JAN232024_01B2203Decided 2024-01-23I-140

AAO remanded this EB-1A petition for a global security expert because the Director improperly dismissed a timely motion…

Remanded Useful for: appeal strategy
EB-1AField: global security expert
The outcome

Good news — this case cleared the first bar

The AAO withdrew the Director's decision and remanded the case because the Director improperly dismissed the motion to reopen as untimely (COVID-19 flexibility allowed 60-day filing window) and failed to address eight of the nine claimed evidentiary criteria in both the RFE and the denial decision.

0 / 3 criteria needed Need 3 more

3 more criteria would trigger a full merits review.

In plain English

The petitioner, a global security expert, sought EB-1A classification and claimed nine evidentiary criteria. The Texas Service Center Director denied the petition after addressing only one criterion in both the RFE and the denial decision, and then improperly dismissed a motion to reopen as untimely despite COVID-19 pandemic filing flexibilities that extended the deadline. The AAO found two independent procedural errors: failure to apply the COVID-19 flexibility allowing a 63-day window, and failure to provide adequate RFE notice and a full denial explanation for the eight unaddressed criteria. Because no merits determination could be made on the incomplete record, the AAO withdrew both decisions and remanded for a complete evaluation of all claimed criteria.

What worked & what failed

What failed: The Director committed procedural errors by addressing only one of the nine claimed evidentiary criteria in both the RFE and the denial, and incorrectly dismissed the motion to reopen without accounting for COVID-19 pandemic filing flexibilities. These errors prevented any substantive merits evaluation from being completed.

Takeaway: When an officer issues a deficient RFE that ignores claimed criteria, document the procedural failure carefully on appeal — the AAO will remand for a complete review. Also verify that all COVID-19-era filing flexibility policies are applied when calculating deadlines for motions filed during that period.

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 Director committed procedural errors by addressing only one of the nine claimed evidentiary criteria in both the RFE and the denial, and incorrectly dismissed the motion to reopen without accounting for COVID-19 pandemic filing flexibilities
  • These errors prevented any substantive merits evaluation from being completed.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Lesser nationally or internationally recognized prizes or awards

Not met

The only criterion the Director actually evaluated; AAO found the Director failed to properly assess all criteria and remanded without ruling on merits.

Membership in associations requiring outstanding achievement

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Published material about the person

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Judging the work of others

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Original contributions of major significance

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Authorship of scholarly articles

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Leading or critical role for distinguished organizations

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

High salary or other significantly high remuneration

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

Commercial successes in the performing arts

Not met

Claimed by petitioner but not addressed by Director in RFE or denial; remanded for proper review.

How the case moved

Completed

I-140 filed

Global security expert

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2024-01-23

AAO decision — Remanded

The AAO withdrew the Director's decision and remanded the case because the Director improperly dismissed the motion to reopen as untimely (COVID-19 flexibility allowed 60-day filing window) and failed to address eight of the nine claimed evidentiary criteria in both the RFE and the denial decision.

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.

Authorities the office relied on
ChawathePetitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence.
Christo'sAAO reviews questions de novo.
KazarianEstablishes two-step review: first count qualifying criteria, then conduct final merits determination.
VisinscaiaSupports the Kazarian two-step framework.
RijalSupports the Kazarian two-step framework.
Matter of M-P-A decision must fully explain the reasons for denial to allow a meaningful opportunity to challenge the determination on appeal.