The Petitioner, a PhD mechanical engineer, proposed to continue research and development of novel thermal batteries and thermal-fluid systems as a lead thermal modeling engineer, aiming to help U.S. industrial decarbonization goals.

Prong 1 — national importanceestablished

“We agree with SCOPS that the Petitioner met Dhanasar's first prong.”

AAO decision text

Prong 2 — well positionednot established · dispositive

“However, a degree in and of itself, is not a basis to determine that a person is well positioned to advance the proposed endeavor.”

“Thus, while this letter is an example of the supportive tone of the recommendation letters, it lacks sufficient specificity in demonstrating how the Petitioner's work has changed the course of other research efforts.”

“The Petitioner therefore has not demonstrated that the number of citations received by her published journals and articles, in and of themselves, reflect a record of success in similar efforts to meet Dhanasar's second prong.”

“the evidence submitted does not sufficiently demonstrate that the Petitioner is well positioned to independently secure funding or lead the advancement of her proposed endeavor.”

“we conclude that the Petitioner has not established that she is well positioned to advance the proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “it lacks sufficient specificity in demonstrating how the Petitioner's work has changed the course of other research efforts.”

  AAO decision text
• citations publications · discounted

  “the Petitioner may not solely rely on CA to prove her contention.”

  AAO decision text
• funding · discounted

  “it cannot be concluded that this grant is indicative of her individual merit or her capacity to independently advance significant research endeavors.”

  AAO decision text
• patents · ignored

  “we are precluded from considering this evidence because a petitioner must establish all eligibility requirements... from the time of filing and continuing through adjudication.”

  AAO decision text
• degree · credited

Where this case turned

• Citations insufficient · p2 — citation counts without qualitative account of impact
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Funding absent · p2 — no documented funding or resources behind the plan
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

AAO affirmed prong 1 was met (unusual, as SCOPS's grant is not commonly upheld outright) but found prong 2 dispositive; extensively engaged with Petitioner's statistical arguments (Clarivate Analytics and OpenAlex citation percentile data) and rejected both as insufficient to independently establish a record of success. AAO also explicitly declined to consider a patent filed 12 days after the petition despite acknowledging the underlying research likely predated filing.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

• 8 C.F.R. 103.2(b)(1)
• 8 C.F.R. 103.2(b)(12)
• 8 C.F.R. 103.3
• Flores v. Garland
• Matter of Katigbak
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(2)

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