MAR122020_01B2203Decided 2020-03-12I-140

An acrobatic performer's EB-1A extraordinary ability petition was dismissed after the AAO found he met only two of the…

Dismissed Useful for: avoid these mistakes
EB-1AField: acrobatic performer / gymnastics
The outcome

This appeal was not successful at this stage

The appeal was dismissed because the petitioner satisfied only two of the required three evidentiary criteria (awards and membership), failing to establish published materials, leading/critical role, or high salary. Without meeting the threshold of three criteria, no final merits determination was required.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

The petitioner, an acrobatic performer and gymnastics coach who had previously received O-1 nonimmigrant status, sought EB-1A classification. The AAO reversed the Director on two criteria — finding he earned nationally/internationally recognized gymnastics medals and was selected for the Great Britain national gymnastics team — but agreed with the Director that he failed three other criteria. Articles submitted for the published materials criterion either were not about him or lacked required identifying information. His role in a large-scale performance production was not shown to be leading or critical among nearly 100 performers. His $60,000 annual salary did not clearly exceed compensation of comparably experienced performers in the field. Because he met only two of the required three criteria, the appeal was dismissed without reaching a final merits determination.

What worked & what failed

What worked: Medals won at junior-level national and international gymnastics championships were accepted as lesser nationally/internationally recognized awards. Selection to the Great Britain national gymnastics team by the national governing body was accepted as membership in an association requiring outstanding achievements judged by recognized national experts.

What failed: Published materials failed because submitted articles were not specifically about the petitioner or lacked required author/date/source information, and the publications were not proven to be major media. The leading/critical role claim failed because the reference letter did not distinguish his contributions from those of the other ~100 performers. The high salary claim failed because his $60,000 salary was not clearly above what experienced performers in the field earned.

Takeaway: For the published materials criterion, submit only articles that focus on you personally and ensure each includes the author, date, and evidence of the publication's major media status. To establish a leading or critical role, obtain letters that quantify your specific impact on the organization — such as revenue contributions or formal responsibilities that set you apart from peers.

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

  • Medals won at junior-level national and international gymnastics championships were accepted as lesser nationally/internationally recognized awards
  • Selection to the Great Britain national gymnastics team by the national governing body was accepted as membership in an association requiring outstanding achievements judged by recognized national experts.

Evidence that wasn't enough alone

  • Published materials failed because submitted articles were not specifically about the petitioner or lacked required author/date/source information, and the publications were not proven to be major media
  • The leading/critical role claim failed because the reference letter did not distinguish his contributions from those of the other ~100 performers
  • The high salary claim failed because his $60,000 salary was not clearly above what experienced performers in the field earned.
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

Reversed in their favor

AAO reversed the Director's denial; found petitioner received nationally and internationally recognized awards including medals at junior-level gymnastics championships in 2013, 2015, and 2016.

Membership in associations requiring outstanding achievement

Reversed in their favor

AAO reversed the Director's denial; found membership on Great Britain national gymnastics team selected by national governing body constitutes membership in an association requiring outstanding achievements judged by recognized national experts.

Published material about the person

Not met

Articles either were not about the petitioner (mentioned him only as a participant), lacked identified authors, lacked dates, or failed to establish the publication qualified as major media.

Leading or critical role for distinguished organizations

Not met

Petitioner was one of nearly 100 performers; reference letter praised his skills but did not demonstrate his role was more prominent or impactful than other performers, and did not provide evidence of increased revenues or other specific organizational impact.

High salary or other significantly high remuneration

Not met

Petitioner earned $60,000/year at time of filing; salary data showed most experienced workers earned up to $58,500 and top 10% earned $85,660+, placing him below the high-salary threshold relative to others in the field.

Evidence that persuaded the AAO

Bronze medal at 2013 Championship, gold medal at 2015 Championship, and silver medal at 2016 Gymnastics Competition

Membership on the Great Britain national gymnastics team from 2014 to 2016

Letter from head coach of Great Britain gymnastics national team confirming selection panel chose petitioner to represent Great Britain at international competitions

Where the evidence fell short

Articles not about the petitioner (he was merely mentioned as a participant among other gymnasts)

Articles lacking identified author, date, or source publication

Northern Echo and Sunderland Echo articles lacking evidence that publications qualify as major media

Reference letter from show gymnastics coach that did not establish leading or critical role distinct from other performers

Salary evidence showing $60,000/year when data indicated most experienced workers earn up to $58,500 and top earners exceed $85,660

W-2 showing only $3,439 in 2018 (partial year)

Officer errors the AAO found

Director incorrectly denied the lesser awards criterion despite documentation of nationally and internationally recognized gymnastics medals

Director incorrectly denied the membership criterion despite evidence of selection to the Great Britain national gymnastics team by the national governing body

How the case moved

Completed

I-140 filed

Acrobatic performer and gymnastics coach

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2020-03-12

AAO decision — Dismissed

The appeal was dismissed because the petitioner satisfied only two of the required three evidentiary criteria (awards and membership), failing to establish published materials, leading/critical role, or high salary. Without meeting the threshold of three criteria, no final merits determination was required.

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)(viii)8 C.F.R. § 204.5(h)(3)(ix)8 C.F.R. § 103.3(b)
KazarianEstablishes the two-step analysis for extraordinary ability: first meet the initial evidentiary criteria, then final merits determination of sustained national or international acclaim.
Matter of PriceHigh salary criterion requires comparison to others performing similar services in the same field; also stands for the proposition that even major-league-level athletes do not automatically meet the extraordinary ability standard.
SkokosSalary comparison for high salary criterion must be to others performing similar duties in the field, not those performing lesser duties.
GrimsonHigh salary criterion requires comparison to others in the same specific role within the field.
MuniSalary comparison must be within the same category of players/performers in the field.
Negro-PlumpeArticles about a show are not considered to be about the individual actor for purposes of the published materials criterion.
Q Data ConsultingPrior approval of a nonimmigrant petition does not preclude denial of a subsequent immigrant petition adjudicated under a different standard.
IKEA USPrior nonimmigrant approval does not bind USCIS in adjudicating an immigrant petition.
Fedin Bros.Prior nonimmigrant approval does not bind USCIS in adjudicating an immigrant petition.
Louisiana PhilharmonicAAO is not bound by service center director's prior nonimmigrant petition approval when adjudicating a separate immigrant petition.