JUL172023_04B5203Decided 2023-07-17I-140

A dentist's EB-2 National Interest Waiver petition was dismissed because she only met one of the six exceptional…

Dismissed Useful for: avoid these mistakes
EB-2-NIWField: dentistry / general dentist
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to meet at least three of the six EB-2 exceptional ability criteria, making her ineligible for the underlying EB-2 classification. Because she could not establish the foundational EB-2 qualification, the national interest waiver question was not reached.

In plain English

A dentist filed an I-140 petition seeking EB-2 classification as an individual of exceptional ability with a national interest waiver. The Texas Service Center Director denied the petition, finding the petitioner met only the academic record criterion of the six required. On appeal, the AAO affirmed the denial, finding that pre-filing dental work experience totaled far less than the ten years required under one criterion, and that the petitioner waived three other criteria by failing to address them specifically in the appeal brief. The AAO also noted concerns about counsel's credibility due to repeated use of incorrect pronouns for the petitioner. Because the petitioner could not clear the foundational EB-2 exceptional ability threshold, the national interest waiver analysis was not reached.

What worked & what failed

What failed: 1. The petitioner failed to demonstrate ten years of full-time pre-filing experience as a dentist — her actual qualifying experience was less than two years combined. 2. The appeal brief failed to specifically argue the license/certification, exceptional salary, and professional membership criteria, causing them to be deemed waived. 3. The appeal contained only general, unsupported assertions that the Director imposed improper standards, without identifying specific errors, which undermined the appeal's persuasiveness.

Takeaway: When appealing a denial, petitioners and counsel must specifically address each criterion the Director rejected, with detailed argument and evidence — vague assertions are insufficient and unaddressed issues will be deemed waived. Counsel should also ensure the appeal brief accurately describes the petitioner to preserve credibility.

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-2-NIW criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The petitioner failed to demonstrate ten years of full-time pre-filing experience as a dentist — her actual qualifying experience was less than two years combined
  • The appeal brief failed to specifically argue the license/certification, exceptional salary, and professional membership criteria, causing them to be deemed waived
  • The appeal contained only general, unsupported assertions that the Director imposed improper standards, without identifying specific errors, which undermined the appeal's persuasiveness.
Find more EB-2-NIW cases with similar evidence patterns →
Evidence that persuaded the AAO

Academic record documentation satisfying 8 C.F.R. § 204.5(k)(3)(ii)(A)

Where the evidence fell short

Employer letters did not establish ten years of full-time experience as a dentist prior to the October 2020 filing date; petitioner's actual pre-filing dentistry experience was approximately six months as a general dentist, thirteen months as a dental assistant, and four months part-time as a dental hygienist

Post-filing U.S. employment as a dentist was not considered because eligibility is assessed at the time of filing

License/certification criterion (8 C.F.R. § 204.5(k)(3)(ii)(C)) was deemed waived because petitioner failed to address it with specificity on appeal

Exceptional salary criterion (8 C.F.R. § 204.5(k)(3)(ii)(D)) was deemed waived because petitioner failed to address it with specificity on appeal

Professional association membership criterion (8 C.F.R. § 204.5(k)(3)(ii)(E)) was deemed waived because petitioner failed to address it with specificity on appeal

Counsel's repeated use of incorrect pronouns for the petitioner raised credibility concerns about the accuracy of assertions on appeal

Officer errors the AAO found

No specific legal errors were found in the Director's decision; the AAO affirmed the Director's findings and dismissed the appeal.

How the case moved

Completed

I-140 filed

General dentist seeking to practice dentistry in the United States

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2023-07-17

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to meet at least three of the six EB-2 exceptional ability criteria, making her ineligible for the underlying EB-2 classification. Because she could not establish the foundational EB-2 qualification, the national interest waiver question was not reached.

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(k)(3)(ii)(A)8 C.F.R. § 204.5(k)(3)(ii)(B)8 C.F.R. § 204.5(k)(3)(ii)(C)8 C.F.R. § 204.5(k)(3)(ii)(D)8 C.F.R. § 204.5(k)(3)(ii)(E)8 C.F.R. § 204.5(k)(3)(ii)(F)8 C.F.R. § 103.2(b)(1)8 C.F.R. § 103.3
ChawathePreponderance of the evidence is the standard of proof for immigration benefit requests
Christa'sAAO reviews questions de novo
DhanasarSets out the three-prong framework for evaluating national interest waiver eligibility
PoursinaUSCIS decision to grant or deny a national interest waiver is discretionary in nature
MartinezPreponderance of the evidence is the applicable standard of proof where no different standard is specified by law
SooHooPreponderance of the evidence standard of proof in immigration proceedings
M-A-S-Issues not raised with specificity on appeal are deemed waived
RizkIssues not raised in a brief are deemed waived (Ninth Circuit)
Martinez-SerranoIssue referred to in statement of case but not discussed in brief body is deemed waived
HoxhaIssue raised in notice of appeal is not waived despite failure to address in brief (Third Circuit)
BagamasbadCourts and agencies are not required to make findings on issues unnecessary to the result reached
M-F-O-Alternative issues on appeal need not be reached where applicant is otherwise ineligible