dismissedDEC162025_03B52032025-12-16 · appeal
This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.
The Petitioner, a medical monitor and physician, proposed to operate a consulting company enhancing U.S. clinical trial safety and regulatory compliance by integrating AI and health information systems.
Field: clinical trial safety and regulatory compliance / medical science · Read the decision (uscis.gov)
Prong 1 — national importancenot established · dispositive
“the record does not demonstrate that his endeavor stands to sufficiently extend beyond his patients and clients to enhance societal welfare on a broader scale”
“without sufficient evidence regarding the projected U.S. economic impact or job creation directly attributable to his future work”
“although the field in which the Petitioner seeks to operate is important, the Petitioner has not offered sufficient information and evidence to demonstrate that the prospective impact of his specific proposed endeavor rises to the level of national importance”
“they do not offer sufficient, detailed, and concrete examples of how the Petitioner's endeavor has the potential for broad and measurable implications for the country”
AAO decision text
How the evidence was treated
- business plan · discounted
“he has not provided sufficient evidence or detailed information to demonstrate that his proposed endeavor will have broader implications”
AAO decision text - recommendation letter · discounted
“they do not offer sufficient, detailed, and concrete examples of how the Petitioner's endeavor has the potential for broad and measurable implications”
AAO decision text - resume experience · discounted
“they are generally immaterial to the first Dhanasar prong-whether a specific, prospective, proposed endeavor has both substantial merit and national importance”
AAO decision text - other · discounted
“alignment with government initiatives alone is insufficient for national importance”
AAO decision text
Where this case turned
- Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
- Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
- Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
- Local, not national scope · p1 — impact confined to clients / a region
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Notable
Petitioner raised an 'Accardi doctrine' argument (agencies must follow their own procedures/policy) alleging SCOPS mischaracterized the endeavor, but the AAO did not separately address this argument and simply proceeded with its own de novo national-importance analysis.
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. 103.3
- 8 C.F.R. 103.5
- Matter of L-A-C-
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