NOV062017_01B2203Decided 2017-11-06I-140

A musician and music teacher's motion to reopen and reconsider an EB-1A denial was denied because he still could not…

Dismissed Useful for: avoid these mistakes
EB-1AField: musician and music teacher
The outcome

This appeal was not successful at this stage

The AAO denied the joint motion to reopen and reconsider, finding the petitioner still met only two of the required three evidentiary criteria (judging and display) and had not established sustained national or international acclaim.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

The petitioner, a musician and music teacher, sought EB-1A classification as an individual of extraordinary ability in the arts. After the Director denied the petition and the AAO dismissed the appeal, he filed a joint motion to reopen and reconsider, claiming he met four additional criteria. The AAO found that the motion to reconsider failed because no legal errors were identified in the prior decision, and the motion to reopen failed because the new evidence still did not establish that his 1981 competition prize was nationally or internationally recognized, and the submitted articles were not 'about the alien' as required by the published material criterion. With only two of the required three criteria met, the petition remained denied and the petitioner's extraordinary ability claim was not established.

What worked & what failed

What worked: The petitioner successfully established the judging criterion and the artistic display criterion, both of which were previously found met and were not disturbed on motion. A 2017 letter from a school official was sufficient to confirm that the petitioner actually received the 1981 competition prize.

What failed: The petitioner could not show the 1981 competition prize was nationally or internationally recognized (no evidence of competitor pool or field attention). The six submitted articles about performances were not 'about the alien' as required, were missing date and author information, and were not shown to be from major media. Claims about the organization's distinguished reputation rested only on the petitioner's own assertions, which were insufficient. The petitioner refused to produce commercial success documents, fatally undermining that criterion.

Takeaway: Petitioners must submit third-party evidence — not just their own assertions — to establish the prestige of awards and organizations. Articles must be demonstrably 'about the alien,' not merely mention them in passing, and must include complete citation information (title, date, and author).

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 established the judging criterion and the artistic display criterion, both of which were previously found met and were not disturbed on motion
  • A 2017 letter from a school official was sufficient to confirm that the petitioner actually received the 1981 competition prize.

Evidence that wasn't enough alone

  • The petitioner could not show the 1981 competition prize was nationally or internationally recognized (no evidence of competitor pool or field attention)
  • The six submitted articles about performances were not 'about the alien' as required, were missing date and author information, and were not shown to be from major media
  • Claims about the organization's distinguished reputation rested only on the petitioner's own assertions, which were insufficient
  • The petitioner refused to produce commercial success documents, fatally undermining that criterion.
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 demonstrated receipt of a 1981 third prize at a competition in Netherlands, but failed to establish the award was nationally or internationally recognized for excellence in the field; insufficient evidence of the pool of competitors or field attention.

Published material about the person

Not met

Six submitted articles discussed music performances and only mentioned the petitioner in passing; articles were not 'about the alien' as required, sources not shown to be major media, and date/author information missing for each piece.

Judging the work of others

Met

Previously found met by the AAO in the appellate decision; not disturbed on motion.

Display of work at artistic exhibitions or showcases

Met

Previously found met by the AAO in the appellate decision; not disturbed on motion.

Leading or critical role for distinguished organizations

Not met

Petitioner claimed concertmaster role from 1989–1996, but failed to establish the organization had a distinguished reputation; petitioner's own assertions were insufficient.

Commercial successes in the performing arts

Not met

Petitioner claimed employment wages from 1986–2011 showed sustained commercial success, but did not provide box office receipts or sales materials and explicitly refused to disclose corresponding documents.

Evidence that persuaded the AAO

May 2017 letter from assistant principal of German school confirming petitioner received a prize at the 1981 competition in Netherlands with a monetary award equivalent to $2,500 USD — sufficient to demonstrate receipt of the award, though not its national/international recognition

Judging criterion previously found met (not disturbed on motion)

Display criterion previously found met (not disturbed on motion)

Where the evidence fell short

Six German-language articles about church concerts — discussed performances and only mentioned petitioner in passing, not 'about the alien' as required; sources not shown to be major media; missing date and author information

1994 letter from lecturer regarding concertmaster role — failed to establish the organization had a distinguished reputation

Employment wages from 1986–2011 as evidence of commercial success — no box office receipts or sales materials provided; petitioner refused to disclose relevant documents

Prior jury reports from 1981 competition — did not name the petitioner as a recipient and did not show national/international recognition of the award

Petitioner's assertions about the organization's distinguished reputation based on location in a historic academic city — insufficient to establish the organization's distinguished reputation

How the case moved

Completed

I-140 filed

Musician and music teacher, including work as a concertmaster and conductor of church concerts

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2017-11-06

AAO decision — Dismissed

The AAO denied the joint motion to reopen and reconsider, finding the petitioner still met only two of the required three evidentiary criteria (judging and display) and had not established sustained national or international acclaim.

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)(iv)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)(x)8 C.F.R. § 204.5(h)(4)8 C.F.R. § 103.5(a)(2)8 C.F.R. § 103.5(a)(3)
KazarianEstablishes the two-step review process: first count whether the petitioner meets the required number of evidentiary criteria, then conduct a final merits determination of whether the evidence establishes sustained national or international acclaim.
VisinscaiaSupports the Kazarian two-step analytical framework for extraordinary ability petitions.
RijalSupports the Kazarian two-step analytical framework for extraordinary ability petitions.
ChawatheTruth is determined not by quantity of evidence alone but by its quality; each piece of evidence must be examined for relevance, probative value, and credibility.
Negro-PlumpeUpholds finding that articles about a performance/show are not 'about the alien' for purposes of the published material criterion.