MAY192022_02B2203Decided 2022-05-19I-140

An EB-1A petition by a sustainable development professional was dismissed because all submitted awards and media…

Dismissed Useful for: avoid these mistakes
EB-1AField: sustainable development and sustainable design solutions
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to satisfy even three of the ten required evidentiary criteria. Awards, published materials, and artistic display criteria were all unmet because evidence pertained to the petitioner's company rather than the petitioner personally.

0 / 3 criteria needed Need 3 more

3 more criteria would trigger a full merits review.

In plain English

The petitioner sought EB-1A classification based on work in sustainable development and sustainable design. The Texas Service Center director denied the petition for failing all ten criteria, and the AAO affirmed on appeal. Three criteria were specifically addressed: awards all went to the petitioner's company rather than the individual; published articles covered the company without substantively featuring the petitioner; and a community development project was not shown to have been displayed at an artistic exhibition or showcase. Because the petitioner could not clear the three-criterion threshold, the AAO did not conduct a Kazarian final merits analysis. The case illustrates the importance of ensuring that evidence is attributable to the individual petitioner, not to their employer or associated company.

What worked & what failed

What failed: 1. All submitted awards were received by the petitioner's company or its projects — none were awarded to the petitioner personally, disqualifying them for the awards criterion. 2. Media coverage articles were about the company and its projects, not about the petitioner as an individual; the petitioner was only briefly quoted in two pieces. 3. The community development project was not shown to have been exhibited at an artistic venue, so the artistic display criterion was not met.

Takeaway: When building an EB-1A petition, ensure all evidence — awards, media coverage, and exhibition records — is explicitly tied to the individual petitioner, not to a company or project they are associated with. Petitioners working through an organization should proactively obtain documentation crediting them personally for contributions and achievements.

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

  • All submitted awards were received by the petitioner's company or its projects — none were awarded to the petitioner personally, disqualifying them for the awards criterion
  • Media coverage articles were about the company and its projects, not about the petitioner as an individual
  • the petitioner was only briefly quoted in two pieces
  • The community development project was not shown to have been exhibited at an artistic venue, so the artistic display criterion was not met.
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

Awards were received by the petitioner's company or its project, not by the petitioner personally; no awarding documentation mentioned the petitioner.

Published material about the person

Not met

Nine articles submitted; only four had required title/date/author, and all articles covered the company rather than the petitioner personally; petitioner only briefly quoted in two articles.

Display of work at artistic exhibitions or showcases

Not met

Community development project was built on land in a city outskirt; petitioner did not demonstrate it was displayed at an artistic exhibition or showcase venue.

Where the evidence fell short

Company-level awards (Asia Pacific Leadership in Green Building Awards 2018, Platinum Certification from Indian Green Building Council, 2018 Architectural Design Award, International Architecture Awards 2015, Certificate of Honorable Mention from Re-Thinking the Future Sustainability Awards, Jury Commendation from Design and Architecture Award) — all received by the company or project, not the petitioner personally

Nine submitted articles — only four had required title/date/author, and none were 'about' the petitioner; petitioner only briefly quoted in two

Evidence of community development project display — not shown to be at an artistic exhibition or showcase

How the case moved

Completed

I-140 filed

Sustainable development and sustainable design professional, co-founder of an environmentally conscious community development company

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2022-05-19

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to satisfy even three of the ten required evidentiary criteria. Awards, published materials, and artistic display criteria were all unmet because evidence pertained to the petitioner's company rather than the petitioner personally.

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)(iii)8 C.F.R. § 204.5(h)(3)(v)8 C.F.R. § 204.5(h)(3)(vii)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 204.5(h)(3)(i)-(x)
KazarianEstablishes two-step review: first count qualifying criteria, then conduct final merits determination for sustained national or international acclaim
VisinscaiaConfirms extraordinary ability designation is extremely restrictive by design
RijalSupports the Kazarian two-part review framework
BagamasbadAgencies are not required to make findings unnecessary to the results they reach; supports reserving unneeded issues
L-A-C-Supports declining to reach alternative issues on appeal where applicant is otherwise ineligible
PriceEven major league athletes do not automatically meet the statutory standards for extraordinary ability
Hamal IIEB-1 visas are reserved for a very small percentage of prospective immigrants
Hamal IEven highly accomplished individuals fail to win the extraordinary ability designation
Lee v. ZiglarArguably one of the most famous baseball players in Korean history did not qualify for extraordinary ability visa as a baseball coach