OCT022023_03B5203Decided 2023-10-02I-140

A special education teacher's national interest waiver petition was dismissed because her proposed work was found to…

Dismissed Useful for: avoid these mistakes
EB-2-NIWField: special education teacher / special needs specialist
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to establish the national importance of her proposed endeavor under the first prong of the Dhanasar framework. Her work as a special education teacher was found to have impact limited to her immediate students rather than broader national implications.

In plain English

The petitioner, a special education teacher working with students with disabilities, sought an EB-2 national interest waiver. While the Director and AAO both agreed she qualified as an advanced degree professional, her petition was denied because she failed to show that her specific teaching work had national importance under the Dhanasar framework's first prong. Expert letters and general statistics about the special education field were insufficient to demonstrate that her individual teaching activities would have broader implications beyond her classroom. The AAO declined to reach the second and third Dhanasar prongs because failure on the first was dispositive.

What worked & what failed

What worked: The petitioner successfully established her EB-2 advanced degree qualification. Evidence of the general importance and societal value of special education was accepted as demonstrating substantial merit of the field.

What failed: Expert opinion letters addressed the national importance of special education as a field rather than the petitioner's specific proposed endeavor, which is the correct legal focus. The petitioner could not show her teaching would impact the broader field or reduce teacher shortages nationally, and claims about expanding her work were unsupported by evidence. Labor shortages alone do not satisfy the national importance requirement because they are addressed through the labor certification process.

Takeaway: NIW petitioners in teaching or service occupations must go beyond showing that their profession is nationally important — they must provide concrete evidence that their specific work will have broader implications beyond their immediate workplace, such as through research, policy influence, scalable programs, or quantifiable national economic or social impact. Relying on field-wide statistics and shortage data, without tying them to the petitioner's unique contribution, is insufficient.

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-2-NIW criteria.

Evidence that moved the needle

  • The petitioner successfully established her EB-2 advanced degree qualification
  • Evidence of the general importance and societal value of special education was accepted as demonstrating substantial merit of the field.

Evidence that wasn't enough alone

  • Expert opinion letters addressed the national importance of special education as a field rather than the petitioner's specific proposed endeavor, which is the correct legal focus
  • The petitioner could not show her teaching would impact the broader field or reduce teacher shortages nationally, and claims about expanding her work were unsupported by evidence
  • Labor shortages alone do not satisfy the national importance requirement because they are addressed through the labor certification process.
Find more EB-2-NIW cases with similar evidence patterns →
Evidence that persuaded the AAO

Petitioner's advanced degree qualifying her as a member of the professions holding an advanced degree

Documentation of national shortage of special education teachers (accepted as showing substantial merit but not national importance)

Evidence of broader societal value of special education (accepted for substantial merit prong only)

Where the evidence fell short

Expert opinion letters from Dr. N-S-A-, Dr. T-G-Z-, and Dr. J-D- — found to address national importance of the field or profession rather than the petitioner's specific proposed endeavor

Letters of support from colleagues and supervisors — found relevant only to the second Dhanasar prong (well-positioned), not national importance

Claim that her work could expand to other states, churches, and schools — unsupported by corroborating evidence

Argument that teacher shortages establish national importance — rejected because petitioner did not show her endeavor would impact or reduce the shortage, and labor shortages are addressed through the labor certification process

General statistics and articles about special education in the United States — insufficient to show the petitioner's specific work has national importance beyond her immediate students

How the case moved

Completed

I-140 filed

Special education teacher working with students with disabilities, including developing individualized education programs (IEPs) and coordinating with parents, therapists, and administrators

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2023-10-02

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to establish the national importance of her proposed endeavor under the first prong of the Dhanasar framework. Her work as a special education teacher was found to have impact limited to her immediate students rather than broader national implications.

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
ChawathePetitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence
Christo'sAAO reviews questions de novo
DhanasarEstablishes the three-prong framework for adjudicating national interest waiver petitions; teaching activities that do not impact the field more broadly do not rise to the level of national importance
PoursinaUSCIS's decision to grant or deny a national interest waiver is discretionary in nature
BagamasbadCourts and agencies are not required to make findings on issues unnecessary to the result they reach
L-A-C-Authority for declining to reach alternative issues on appeal where an applicant is otherwise ineligible