JUN262015_01B2203Decided 2015-06-26I-140

An EB-1A petition by a transplantation researcher was dismissed after the AAO found he met only two of the required…

Dismissed Useful for: avoid these mistakes
EB-1AField: sciences — transplantation research, specifically organ preservation, ischemia reperfusion injury, and cardiac death donor livers
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner satisfied only two of the required three EB-1A evidentiary criteria (judging and scholarly articles), failing to demonstrate original contributions of major significance. Without meeting the minimum three-criteria threshold, the petition could not advance to a final merits determination.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

A biomedical researcher specializing in organ transplantation and ischemia reperfusion injury filed an EB-1A self-petition that was denied by the Texas Service Center Director and then appealed to the AAO. The AAO agreed that the petitioner satisfied the judging criterion (peer review of manuscripts) and the scholarly articles criterion, but found he did not meet the original contributions criterion because his expert letters were largely conclusory or prospective, his citation record was only moderate, and no evidence showed that other researchers had built substantially on his work. Because the petitioner could not clear the three-criteria threshold under the Kazarian two-step framework, the AAO did not conduct a final merits determination and dismissed the appeal. The decision underscores that having an approved EB-2 NIW petition does not satisfy the higher EB-1A standard for contributions of major significance.

What worked & what failed

What worked: The petitioner successfully demonstrated peer review activity for multiple journals (judging criterion) and authorship of multiple published scholarly articles (scholarly articles criterion), which were accepted by both the Director and the AAO.

What failed: Expert reference letters failed because they were largely conclusory, used prospective language about future benefits, or lacked specific examples of field-wide impact; the citation record for individual articles was described as only moderate with no showing of unusual reliance by citing authors; poster awards were not shown to be nationally or internationally recognized; and media/conference coverage was insufficient to demonstrate contributions of major significance.

Takeaway: For EB-1A original contributions claims, petitioners should submit concrete, objective evidence — such as detailed citation analyses showing heavy reliance on their specific findings, letters from independent researchers explaining exactly how they used the petitioner's work in their own studies, and documentation of field-wide adoption of methods or findings — rather than relying primarily on expert letters that repeat regulatory language or describe only potential future impact.

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 demonstrated peer review activity for multiple journals (judging criterion) and authorship of multiple published scholarly articles (scholarly articles criterion), which were accepted by both the Director and the AAO.

Evidence that wasn't enough alone

  • Expert reference letters failed because they were largely conclusory, used prospective language about future benefits, or lacked specific examples of field-wide impact
  • the citation record for individual articles was described as only moderate with no showing of unusual reliance by citing authors
  • poster awards were not shown to be nationally or internationally recognized
  • and media/conference coverage was insufficient to demonstrate contributions of major significance.
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

Petitioner submitted poster awards but did not argue them under this criterion; AAO declined to evaluate them here and addressed them under original contributions instead.

Membership in associations requiring outstanding achievement

Not met

Petitioner submitted evidence of professional memberships but did not show the associations require outstanding achievements of members; AAO declined to find criterion met.

Published material about the person

Not met

AAO noted a separate criterion exists for published material; media coverage cited by petitioner was insufficient to establish contributions of major significance and was not evaluated as meeting this distinct criterion.

Judging the work of others

Met

Director and AAO both found criterion met; petitioner provided evidence of reviewing manuscripts for multiple journals.

Original contributions of major significance

Not met

Director denied; AAO affirmed denial. Expert letters were largely conclusory or forward-looking; citation record was moderate; no evidence that others built substantially on petitioner's work in a manner demonstrating major significance.

Authorship of scholarly articles

Met

Director and AAO both found criterion met; petitioner had multiple published articles in appropriate journals.

Evidence that persuaded the AAO

Evidence of peer review of manuscripts for multiple journals — satisfied judging criterion (iv)

Multiple published scholarly articles in professional journals — satisfied scholarly articles criterion (vi)

Where the evidence fell short

Expert reference letters characterized as largely conclusory, forward-looking, or lacking specific examples of field-wide impact

Citation record for individual articles described as moderate; no showing that citing authors placed unusual reliance on petitioner's work

Poster of Distinction Awards — not shown to be nationally or internationally recognized; no evidence of field impact after conference dissemination

Media/conference coverage — conference report described as highlighting selected presentations, not reporting important breakthroughs; website article lacked evidence of reach and importance in field

Product website listing petitioner's work as a reference — available 'for research use only' and did not demonstrate actual field-wide implementation

Dr. [redacted]'s claim that petitioner's 2012 article was 'wildly cited' and ranked in top one percent — unsupported by submitted evidence; citation record showed only moderate citations

Expert assertions that petitioner's work would lead to novel therapies or future benefits — prospective impact does not satisfy requirement that contributions have already been realized

Officer errors the AAO found

Petitioner argued director improperly discounted expert letters that used the word 'young' to describe petitioner; AAO partially agreed that three letters did not use the term to qualify his accomplishments, but found one letter explicitly compared him only to other young scientists, which does not demonstrate field-wide impact.

Petitioner argued director failed to consider Dr. [redacted]'s letter and the product listing citing petitioner's work; AAO found these were considered but insufficient — the product listing showed only availability for research use, not actual field-wide use.

How the case moved

Completed

I-140 filed

Physician-scientist / biomedical researcher specializing in transplantation surgery and organ preservation

Completed

Director, Texas Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2015-06-26

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner satisfied only two of the required three EB-1A evidentiary criteria (judging and scholarly articles), failing to demonstrate original contributions of major significance. Without meeting the minimum three-criteria threshold, the petition could not advance to a final merits determination.

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(h)(2)8 C.F.R. § 204.5(h)(3)8 C.F.R. § 204.5(h)(3)(i)8 C.F.R. § 204.5(h)(3)(ii)8 C.F.R. § 204.5(h)(3)(iii)8 C.F.R. § 204.5(h)(3)(iv)8 C.F.R. § 204.5(h)(3)(v)8 C.F.R. § 204.5(h)(3)(vi)8 C.F.R. § 204.5(h)(3)(x)8 C.F.R. § 103.58 C.F.R. § 103.5(a)(1)(ii)8 C.F.R. § 2.1 (2003)8 C.F.R. § 103.1(f)(3)(iii) (2003)
Kazarian (2010)Establishes two-step review: first count qualifying criteria, then conduct final merits determination if threshold met
Kazarian (2009)Vague, solicited letters from colleagues not specifically identifying contributions are insufficient; published news articles are not sufficient under original contributions criterion
RijalAffirms USCIS proper application of Kazarian two-step analysis
VisinscaiaUSCIS appropriately applied two-step review; contributions of major significance require demonstrated impact on the field; limited weight to uncorroborated practitioner assertions was not arbitrary and capricious
ChawatheTruth determined by quality of evidence, not quantity; each piece examined for relevance, probative value, and credibility
SofficiGoing on record without supporting documentary evidence is not sufficient to meet burden of proof
Fedin Bros.Using statutory or regulatory language does not satisfy petitioner's burden of proof
Avyr AssociatesUsing statutory or regulatory language does not satisfy petitioner's burden of proof
1756, Inc.USCIS need not accept primarily conclusory assertions
Silverman/APWUStatutory/regulatory language is not superfluous; 'major significance' has substantive meaning
SoltaneAAO maintains de novo review of all questions of fact and law
Matter of S-A-Corroborative testimonial and documentary evidence is required; if testimony lacks specificity there is greater need for corroborating evidence
Matter of Caron InternationalUSCIS may use expert opinion letters as advisory opinions but retains final determination authority; submission is not presumptive evidence of eligibility
Matter of V-K-Expert opinion does not purport to be evidence of fact; USCIS may give less weight to uncorroborated or questionable opinions
Matter of OtiendePetitioner bears burden of establishing eligibility for immigration benefit sought
Matter of AurelioUSCIS is the sole authority with jurisdiction to decide visa petitions