MAR162015_02B2203Decided 2015-03-16I-140

An IT systems architect's EB-1A extraordinary ability petition was dismissed after failing to meet even three of the…

Dismissed Useful for: avoid these mistakes
EB-1AField: systems architect in the information technology field; specifically Business Intelligence, Data Warehousing and ETL (Extract, Transform and Load) processes
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 ten regulatory criteria for extraordinary ability. The AAO also reversed the director's finding that the petitioner met the high salary criterion.

0 / 3 criteria needed Need 3 more

3 more criteria would trigger a full merits review.

In plain English

The petitioner, a data integration/systems architect in the IT field, sought EB-1A classification but the AAO dismissed the appeal, finding he satisfied none of the ten regulatory criteria. The AAO reversed the director's finding on the high salary criterion because the petitioner's wage comparisons relied only on average, median, and prevailing wage data rather than comparing his earnings to top earners doing similar work. For the judging criterion, routine duties like performance reviews, recruiting interviews, and testing vendor software did not constitute formal participation as a judge of others' work. For the leading/critical role criterion, unsupported assertions about employers' distinguished reputations and the petitioner's hierarchical standing were insufficient. Because fewer than three criteria were satisfied, no final merits determination was conducted, though the AAO noted that even in aggregate the evidence fell short.

What worked & what failed

What failed: 1. Salary evidence based on average, median, or prevailing wages failed because the criterion requires comparison to top earners doing similar work, not just above-average pay. 2. Letters describing routine supervisory duties (performance reviews, recruiting, coworker feedback, vendor software testing) were insufficient for the formal judging criterion. 3. Claims about working in critical roles for named companies were unsupported by documentary evidence of those companies' distinguished reputations or the petitioner's specific place in their organizational hierarchy.

Takeaway: For the high salary criterion, petitioners must submit direct comparisons to high earners in the same specialty role—not just average or prevailing wages. For judging and critical role criteria, formal documentation (panel invitations, organizational charts, executive-level attestations with supporting records) is essential; employer reference letters describing ordinary work duties will not suffice.

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

  • See summary above for details.

Evidence that wasn't enough alone

  • Salary evidence based on average, median, or prevailing wages failed because the criterion requires comparison to top earners doing similar work, not just above-average pay
  • Letters describing routine supervisory duties (performance reviews, recruiting, coworker feedback, vendor software testing) were insufficient for the formal judging criterion
  • Claims about working in critical roles for named companies were unsupported by documentary evidence of those companies' distinguished reputations or the petitioner's specific place in their organizational hierarchy.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Judging the work of others

Not met

Petitioner's routine supervisory duties—performance reviews, recruiting, testing vendor software products, reviewing coworker output—were found not to constitute formal participation as a judge of the work of others in the field. Director had also denied this criterion.

Leading or critical role for distinguished organizations

Not met

Petitioner failed to demonstrate that the organizations he worked for (as consultant or employee) had a distinguished reputation, and failed to show his role was leading or critical within the organizational hierarchy. Unsupported assertions in letters were given little weight. Director had also denied this criterion.

High salary or other significantly high remuneration

Reversed in their favor

Director had granted this criterion, but AAO reversed, finding the salary evidence (W-2s, pay stubs, offer letters, average/median/prevailing wage comparisons) did not demonstrate high remuneration relative to others in the field. Post-filing earnings were excluded. Comparison data used average, median, or prevailing wages rather than top-earner benchmarks.

Where the evidence fell short

Letters from supervisors and colleagues describing routine performance reviews, recruiting interviews, and feedback on coworkers' work as 'judging'—not accepted as formal judging under criterion iv

Letter from Big Data Systems Engineer describing petitioner's testing and review of a vendor software product—not accepted as judging the work of others in the field

Letters asserting petitioner performed critical roles for named companies without documentary corroboration of those companies' distinguished reputations

W-2 forms and pay stubs showing earnings of ~$80,000–$101,000 per year without comparison to top earners in the field

Salary search results showing 'average' or 'median' salaries for related job titles—not an appropriate benchmark for high salary criterion

O-NET median wage data ($81,140 for 2012)—median comparison insufficient to show high salary

Foreign Labor Certification prevailing wage data—prevailing wage not equivalent to high salary relative to others in the field

H-1B LCA filings listing Level II and Level III prevailing wages for Data Integration Architect—insufficient comparison benchmark

Offer letter showing $228,000 salary from a prospective employer with no evidence of actual earnings from that employer

Post-filing pay stubs and bonus received after February 18, 2014 filing date—ineligible for consideration

Officer errors the AAO found

Director incorrectly granted the high salary criterion (criterion ix) where the petitioner's salary evidence only showed earnings above average or prevailing wage, not high remuneration relative to others in the field.

How the case moved

Completed

I-140 filed

Systems/Data Integration Architect in information technology

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2015-03-16

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to meet at least three of the ten regulatory criteria for extraordinary ability. The AAO also reversed the director's finding that the petitioner met the high salary criterion.

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)-(x)8 C.F.R. § 204.5(h)(3)(iv)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 204.5(h)(3)(ix)8 C.F.R. § 204.5(h)(4)8 C.F.R. § 103.2(b)(1)8 C.F.R. § 103.2(b)(12)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)
KazarianEstablishes two-step review: first count qualifying criteria, then conduct final merits determination if threshold met.
RijalAffirmed USCIS proper application of the Kazarian two-step framework.
VisinscaiaAffirmed USCIS appropriately applied the two-step Kazarian review; also upheld giving limited weight to uncorroborated assertions from practitioners.
ChawatheEligibility is determined by quality of evidence, not quantity; USCIS examines each piece for relevance, probative value, and credibility.
SoltaneAAO maintains de novo review of all questions of fact and law.
1756, Inc.An agency need not credit conclusory assertions in immigration benefits adjudications.
Matter of Y-B-Where testimonial evidence lacks specificity, detail, or credibility, there is a greater need for corroborative evidence.
Matter of SofficiGoing on record without supporting documentary evidence is insufficient to meet the burden of proof.
SkokosAverage salary information for those performing lesser duties is not a proper comparison to others in the field for the high salary criterion.
MuniHigh salary must be compared to others performing similar work (e.g., NHL defensive players compared to other NHL defensemen).
GrimsonHigh salary analysis requires comparison to similarly situated peers in the same field and role.
Matter of PriceHigh salary is assessed by comparing the petitioner's earnings to those of peers doing similar work.
Matter of KatigbakEligibility must be established at the time of filing.
Matter of OtiendeIn visa petition proceedings the petitioner bears the burden of establishing eligibility for the benefit sought.
Matter of AurelioUSCIS is the sole authority with jurisdiction to decide visa petitions.