JUN022020_04B2203Decided 2020-06-02I-140

An experienced strategic port planner's motions to reopen and reconsider his EB-1A denial were both dismissed because…

Dismissed Useful for: avoid these mistakes
EB-1AField: strategic port planning, maritime and civil infrastructure development
The outcome

This appeal was not successful at this stage

The AAO dismissed both the motion to reconsider and the motion to reopen. The petitioner failed to establish any additional evidentiary criteria beyond the two previously granted (leading/critical role and high salary), falling short of the required three.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

The petitioner, a strategic port planner with over 25 years of experience, sought EB-1A classification but was found to meet only two of the required three evidentiary criteria (leading/critical role and high salary). On combined motions to reopen and reconsider, he argued he also met membership, original contributions, and scholarly articles criteria. The AAO dismissed both motions, finding that new evidence of a board directorship and consulting project work postdated the November 2017 filing date and thus could not be considered. Reference letters supporting original contributions were found too vague to demonstrate major significance in the field. The scholarly articles criterion was improperly raised for the first time on motion after having been abandoned on appeal.

What worked & what failed

What worked: The petitioner successfully established two criteria — holding a leading or critical role (criterion viii) and receiving a high salary (criterion ix) — which were accepted on prior appeal and remained undisturbed.

What failed: New membership evidence (board directorship) postdated the filing date and could not cure the deficiency. Reference letters for original contributions lacked the specificity needed to show major significance in the field. New project evidence also postdated filing. The scholarly articles claim was raised too late, having been abandoned on appeal.

Takeaway: Petitioners must ensure all supporting evidence clearly predates the filing date and that reference letters articulate specific, concrete contributions with measurable impact on the field — vague assertions of excellence are insufficient. New claims of eligibility must be raised at the earliest procedural stage, as they will be rejected if first advanced in a post-appellate motion.

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

  • The petitioner successfully established two criteria — holding a leading or critical role (criterion viii) and receiving a high salary (criterion ix) — which were accepted on prior appeal and remained undisturbed.

Evidence that wasn't enough alone

  • New membership evidence (board directorship) postdated the filing date and could not cure the deficiency
  • Reference letters for original contributions lacked the specificity needed to show major significance in the field
  • New project evidence also postdated filing
  • The scholarly articles claim was raised too late, having been abandoned on appeal.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Membership in associations requiring outstanding achievement

Not met

PIANC and ALC memberships did not require outstanding achievements as judged by recognized experts. New evidence of board directorship postdated the filing date and could not be considered.

Published material about the person

Not met

Petitioner did not claim this criterion on motion; previously considered and not satisfied.

Original contributions of major significance

Not met

Reference letters lacked specifics about contributions and their major significance. New project evidence postdated filing. Articles submitted did not mention the petitioner.

Authorship of scholarly articles

Not met

Not previously claimed on appeal; treated as improperly raised on motion. Master's thesis archived but 'not available from this repository' does not establish publication in major media.

Leading or critical role for distinguished organizations

Met

Previously granted on appeal; not disputed on motion.

High salary or other significantly high remuneration

Met

Previously granted on appeal; not disputed on motion.

How the case moved

Completed

I-140 filed

Strategic port planner with over 25 years of experience in maritime and civil infrastructure development

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2020-06-02

AAO decision — Dismissed

The AAO dismissed both the motion to reconsider and the motion to reopen. The petitioner failed to establish any additional evidentiary criteria beyond the two previously granted (leading/critical role and high salary), falling short of the required 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.

Authorities the office relied on
KazarianEstablishes the two-step framework for evaluating extraordinary ability petitions
SepulvedaIssues not raised on appeal are abandoned
HristovClaims not raised on appeal to the AAO are considered abandoned
Silverman/APWUStatutory terms are not superfluous; 'major significance' has independent meaning
KatigbakEligibility must be established from the time of filing through adjudication
IzummiA petition cannot be approved based on facts that arise only after filing
BardouilleUSCIS cannot consider facts that come into being only subsequent to the filing of a petition
O-S-G-A motion to reconsider is not a vehicle to resubmit the same brief and generally allege error