NOV122024_04B2203Decided 2024-11-12I-140

A civil/transportation engineer's EB-1A petition was dismissed after the AAO found he met only one of three required…

Dismissed Useful for: avoid these mistakes
EB-1AField: civil engineer / transportation engineering
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner met only one of the required three evidentiary criteria (judging). The AAO also reversed the Director's finding that the published material criterion was met.

1 / 3 criteria needed Need 2 more

2 more criteria would trigger a full merits review.

In plain English

A civil engineer specializing in transportation infrastructure sought EB-1A classification but was denied by the Texas Service Center for failing to meet three evidentiary criteria. On appeal, the AAO upheld most of the Director's findings and went further by reversing the one criterion the Director had granted — published material — because articles appeared in non-qualifying outlets lacking required author/date information or major media standing. The petitioner's ASCE membership fell short because the 'Member' grade does not require outstanding achievements judged by recognized experts. Recommendation letters about original engineering contributions described only employer-level impact without showing broader field-wide significance. The petitioner's salary of approximately $97,500–$105,000 did not exceed the 75th percentile benchmark for civil engineers nationally, failing to demonstrate a 'high salary.' Because the petitioner could not clear even the initial three-criteria threshold, no final merits determination was conducted.

What worked & what failed

What worked: The petitioner successfully demonstrated the judging criterion, which was affirmed by the AAO.

What failed: 1) Published material: articles lacked required metadata or appeared on non-qualifying platforms with unproven major media status. 2) Original contributions: recommendation letters described project-specific accomplishments but failed to show influence on the broader civil engineering field beyond the employer. 3) High salary: earnings at or below the 75th BLS percentile for civil engineers do not constitute a 'high salary'; comparison data from self-reporting salary websites was also unreliable.

Takeaway: For EB-1A petitions in engineering, petitioners must document field-wide impact of original contributions with independent corroborating evidence (citations, adoption by others, industry recognition), not just employer or client testimonials. Salary evidence should target the 90th percentile or above using authoritative BLS data, and any published media must demonstrably qualify as professional or major trade publications with complete bibliographic information.

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 the judging criterion, which was affirmed by the AAO.

Evidence that wasn't enough alone

  • 1) Published material: articles lacked required metadata or appeared on non-qualifying platforms with unproven major media status
  • 2) Original contributions: recommendation letters described project-specific accomplishments but failed to show influence on the broader civil engineering field beyond the employer
  • 3) High salary: earnings at or below the 75th BLS percentile for civil engineers do not constitute a 'high salary'
  • comparison data from self-reporting salary websites was also unreliable.
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

Not contested on appeal; deemed abandoned.

Membership in associations requiring outstanding achievement

Not met

ASCE 'Member' grade does not require 'outstanding achievements' as judged by recognized national/international experts; higher grades (Fellow, Distinguished Member) set a higher bar.

Published material about the person

Reversed in their favor

AAO reversed the Director's grant of this criterion. The Globee article lacked required date and author; NewsBreak.com article appeared to be promotional content on an open-source platform, and petitioner failed to show NewsBreak.com qualifies as major media.

Judging the work of others

Met

Director found this criterion met; AAO affirmed.

Original contributions of major significance

Not met

Recommendation letters described impact on employer projects but failed to show substantial influence beyond the employer or widespread recognition in the field.

Leading or critical role for distinguished organizations

Not met

Not contested on appeal; deemed abandoned.

High salary or other significantly high remuneration

Not met

Base salary of $97,500–$105,000 did not exceed the 75th percentile for civil engineers nationally; comparison data from Payscale, Salary.com, and Comparably was unreliable self-reported data, and petitioner showed only above-average rather than high salary.

Evidence that persuaded the AAO

Judging criterion (8 C.F.R. § 204.5(h)(3)(iv)) was met — affirmed from Director's decision

Where the evidence fell short

ASCE 'Member' certificate and bylaws — membership grade does not require outstanding achievements judged by recognized experts

Globee article — missing required date and author information

NewsBreak.com article — likely promotional/marketing content on open-source platform; insufficient evidence of major media status

Similarweb.com traffic data for NewsBreak.com — limited comparison set cherry-picked by petitioner, excluding higher-readership local outlets

Recommendation letters on original contributions — described project-level impact without showing influence on the broader field beyond employer clients

Texas DOT public meeting notice — did not mention petitioner or highlight major significance of contributions

Base salary of $97,500–$105,000 — below the 75th percentile national BLS benchmark for civil engineers

Payscale.com, Salary.com, and Comparably.com salary data — self-reported, potentially unreliable comparison

Officer errors the AAO found

The Director erroneously found the published material criterion (8 C.F.R. § 204.5(h)(3)(iii)) satisfied; the AAO reversed this finding because the Globee article lacked required date and author, and the NewsBreak.com article was likely promotional content on an open-source platform without demonstrated major media status.

How the case moved

Completed

I-140 filed

Civil/transportation engineer working on roadway design and infrastructure projects in Texas

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.

2024-11-12

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner met only one of the required three evidentiary criteria (judging). The AAO also reversed the Director's finding that the published material criterion was met.

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.

Find this useful? A coffee helps keep Case Reviewer free and ad-free.

Buy me a coffee
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)(viii)8 C.F.R. § 204.5(h)(3)(ix)
ChawathePetitioner bears burden of proof by preponderance of the evidence
Christa'sAAO reviews questions de novo
KazarianEstablishes two-step review: count criteria first, then conduct final merits determination
VisinscaiaExtraordinary ability designation is extremely restrictive by design
RijalSupports Kazarian two-step framework
O-R-E-Issues not raised on appeal are waived
R-A-M-Issues not raised on appeal are waived
StrategatiOriginal contributions criterion requires substantial influence beyond one's employers, clients, or customers
AminEvidence insufficient for original contributions where it did not show widespread replication of petitioner's invention
PriceHigh salary must be compared to others performing similar services; even major-league athletes do not automatically qualify for extraordinary ability
SkokosSalary information for those performing lesser duties is not a valid comparison to others in the field
CrimsonHigh salary must be compared against peers performing similar roles
MuniHigh salary must be compared against peers performing similar roles
BagamasbadAgencies not required to make findings on issues unnecessary to the result reached
L-A-C-Declining to reach alternative issues on appeal where applicant is otherwise ineligible
Hamal IIEB-1 visas reserved for a very small percentage of prospective immigrants
Hamal IEven highly accomplished individuals may fail to meet the extraordinary ability standard
LeeEven one of the most famous baseball players in Korean history did not qualify for extraordinary ability visa as a coach