OCT042024_02B2203Decided 2024-10-04I-140

A Brazilian jiu-jitsu coach appealed a denial of his EB-1A petition; the AAO reversed the Director's improper dismissal…

Remanded Useful for: appeal strategy
EB-1AField: Brazilian jiu-jitsu coach, athlete, and referee
The outcome

Good news — this case cleared the first bar

The AAO withdrew the Director's denial after finding the Petitioner met a third evidentiary criterion (lesser awards) that the Director had improperly dismissed. Because no final merits determination had been made, the case was remanded to the Director to conduct that analysis.

3 / 3 criteria needed Threshold cleared ✓

Next step: a full merits review weighing all the evidence together.

In plain English

The Nebraska Service Center denied the petition, finding the petitioner met only two of the required three evidentiary criteria because the Director refused to consider his athletic awards on the grounds that he now works as a coach. On appeal, the AAO found this was legal error under USCIS Policy Manual guidance, which permits proportionate consideration of athletic achievements when the coaching career overlaps or follows an acclaimed athletic career. The AAO found that a bronze medal at the 2017 national championship in the adult blackbelt category satisfied the lesser awards criterion, bringing the total to three criteria met. Because the Director never conducted a final merits determination, the AAO remanded the case for that analysis rather than deciding it outright.

What worked & what failed

What worked: The petitioner's 2017 national championship bronze medal in the adult blackbelt division was accepted as a qualifying lesser nationally recognized award, supported by sports media coverage confirming the event's prestige. Evidence of judging/refereeing activity and a leading role in a distinguished organization was already accepted by the Director and undisturbed on appeal.

What failed: Most of the other claimed competition medals were not individually found qualifying. The remaining four claimed criteria (membership, published material, artistic display, and one other) were not resolved and await review on remand.

Takeaway: Athletes transitioning to coaching should document both careers carefully and cite the USCIS Policy Manual's athlete-to-coach guidance explicitly; officers cannot simply disregard athletic achievements when the coaching career overlaps or grew directly from that athletic background.

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's 2017 national championship bronze medal in the adult blackbelt division was accepted as a qualifying lesser nationally recognized award, supported by sports media coverage confirming the event's prestige
  • Evidence of judging/refereeing activity and a leading role in a distinguished organization was already accepted by the Director and undisturbed on appeal.

Evidence that wasn't enough alone

  • Most of the other claimed competition medals were not individually found qualifying
  • The remaining four claimed criteria (membership, published material, artistic display, and one other) were not resolved and await review on remand.
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

Reversed in their favor

Director denied this criterion because petitioner intends to work as a coach, disregarding athletic competition awards. AAO reversed, finding a bronze medal at the 2017 national championship in the adult blackbelt category qualifies as a nationally recognized award under the plain language of the regulation.

Membership in associations requiring outstanding achievement

Not met

Claimed by petitioner but not resolved by AAO; remanded without reaching this criterion.

Published material about the person

Not met

Claimed by petitioner but not resolved by AAO; remanded without reaching this criterion.

Judging the work of others

Met

Director found this criterion met; AAO did not disturb that finding.

Display of work at artistic exhibitions or showcases

Not met

Claimed by petitioner but not resolved by AAO; remanded without reaching this criterion.

Leading or critical role for distinguished organizations

Met

Director found this criterion met; petitioner plays a leading or critical role for an organization with a distinguished reputation. AAO did not disturb that finding.

Evidence that persuaded the AAO

Bronze medal in the adult blackbelt category at the 2017 national championship, supported by sports media articles describing it as one of the biggest events of the most well-established jiu-jitsu federation gathering top American black belts.

Evidence of participation as a judge/referee in the field (criterion iv met by Director).

Evidence of a leading or critical role for an organization with a distinguished reputation (criterion viii met by Director).

Where the evidence fell short

Most competition medals and awards not individually found qualifying; only the 2017 national championship bronze medal was specifically identified as meeting the lesser awards criterion.

Evidence of other claimed criteria (membership, published material, artistic display) was not evaluated by the AAO and left for remand.

Officer errors the AAO found

Director improperly disregarded the petitioner's athletic competition awards solely because he intends to work as a coach, contrary to USCIS Policy Manual guidance on athlete-to-coach transitions.

Director failed to conduct a final merits determination after finding two criteria met, leaving the adjudication incomplete.

How the case moved

Completed

I-140 filed

Brazilian jiu-jitsu coach, competitive athlete, and referee

Completed

Nebraska Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2024-10-04

AAO decision — Remanded

The AAO withdrew the Director's denial after finding the Petitioner met a third evidentiary criterion (lesser awards) that the Director had improperly dismissed. Because no final merits determination had been made, the case was remanded to the Director to conduct that analysis.

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)(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)(vii)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 103.3
ChawatheThe petitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence.
Christo'sThe AAO reviews questions de novo.
KazarianEstablishes the two-step extraordinary ability review: first count qualifying criteria, then conduct a final merits determination on the totality of the evidence.
VisinscaiaSupports the Kazarian two-part review framework.
RijalSupports the Kazarian two-part review framework.
BagamasbadAgencies are not required to make purely advisory findings on issues unnecessary to the ultimate decision.
L-A-C-Supports declining to reach alternative issues on appeal where they are unnecessary to the decision.