JUN072017_01B4203Decided 2017-06-07I-140

AAO dismissed an EB-1C petition for a newspaper publisher's Pre Press Manager after finding multiple inconsistent job…

Dismissed Useful for: avoid these mistakes
EB-1CField: newspaper publishing / prepress operations
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to establish that the beneficiary would be employed in a managerial capacity in the U.S. The job descriptions were inconsistent, vague, and overlapped with subordinate duties, preventing a finding of primarily managerial work.

In plain English

A newspaper publishing company sought to permanently employ a foreign worker as its Pre Press Manager under the EB-1C multinational executive or manager classification. The Texas Service Center denied the petition on grounds that neither the proposed U.S. employment nor the prior foreign employment was demonstrated to be managerial. On appeal, the AAO focused solely on the U.S. employment issue, finding it dispositive. The petitioner submitted multiple contradictory job descriptions across filings, failed to provide specific time allocations per duty, and presented subordinate job duties that were identical to the beneficiary's own duties — undermining any claim of function management. The AAO also found that staffing evidence (W-2s, organizational charts) was internally inconsistent and could not confirm adequate support staff to relieve the beneficiary from operational tasks. The appeal was dismissed.

What worked & what failed

What failed: 1. Multiple inconsistent job descriptions across the initial petition, RFE response, and motion to reopen made it impossible to determine what the beneficiary would actually do. 2. The beneficiary's listed job duties were identical to those of claimed subordinates, directly undermining the managerial/function manager claim. 3. Staffing evidence (W-2s, organizational charts) contradicted each other and could not establish that sufficient support staff existed to relieve the beneficiary from non-managerial work.

Takeaway: For EB-1C petitions, petitioners must provide a single, detailed, consistent job description with specific time allocations per duty from the outset, and ensure that the beneficiary's duties are clearly distinguishable from those of subordinates. Inconsistencies between filings will severely undermine credibility and are very difficult to overcome on appeal.

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-1C criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • Multiple inconsistent job descriptions across the initial petition, RFE response, and motion to reopen made it impossible to determine what the beneficiary would actually do
  • The beneficiary's listed job duties were identical to those of claimed subordinates, directly undermining the managerial/function manager claim
  • Staffing evidence (W-2s, organizational charts) contradicted each other and could not establish that sufficient support staff existed to relieve the beneficiary from non-managerial work.
Find more EB-1C cases with similar evidence patterns →
Where the evidence fell short

Multiple inconsistent job descriptions that did not align with each other or explain the discrepancies

Organizational charts that contradicted the initial supporting statement regarding subordinate employees and hierarchy

W-2 wage statements that corroborated far fewer subordinates than claimed

Time allocation claims (e.g., 60% managing function) unsupported by specific duty breakdowns

Third-party printing agreements, invoices, and sales reference documents submitted on appeal without explanation of relevance

Job duties for the beneficiary that were identical to those of claimed subordinates, undermining the managerial claim

Motion to reopen with yet another different job description inconsistent with prior submissions

How the case moved

Completed

I-140 filed

Pre Press Manager at a newspaper publishing company

Completed

Texas Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2017-06-07

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to establish that the beneficiary would be employed in a managerial capacity in the U.S. The job descriptions were inconsistent, vague, and overlapped with subordinate duties, preventing a finding of primarily managerial work.

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(j)(3)8 C.F.R. § 204.5(j)(4)(i)8 C.F.R. § 204.5(j)(5)8 C.F.R. § 204.5(j)(2)
Champion WorldPetitioner must show beneficiary will perform high-level responsibilities and be primarily engaged in managerial duties, not ordinary operational activities
Family Inc.Beneficiary must be primarily engaged in managerial duties as opposed to ordinary operational activities
Matter of Z-A-, Inc.Petitioner's description of daily duties must demonstrate that the beneficiary will manage the function rather than perform duties related to the function
Matter of HoUnresolved material inconsistencies may lead to reevaluation of reliability and sufficiency of other evidence; petitioner must resolve inconsistencies with independent, objective evidence
Fedin Bros.The actual duties themselves reveal the true nature of the employment
AnetekhaiUSCIS may reject assertions in the petition that it finds reason to believe are not true
Lu-Ann Bakery ShopUSCIS may reject assertions in the petition that it finds reason to believe are not true
Systronics Corp.USCIS may reject assertions in the petition that it finds reason to believe are not true
Matter of Church Scientology Int'lAn employee who primarily performs tasks to produce a product or provide services is not primarily employed in a managerial or executive capacity; prior approvals do not bind USCIS to approve a petition where eligibility is not demonstrated
Sussex Eng'gUSCIS is not required to approve petitions merely because of prior approvals that may have been erroneous
La. Philharmonic OrchestraAAO is not bound to follow a contradictory decision of a service center
Matter of ChawathePetitioner must support its assertions with relevant, probative, and credible evidence