The Petitioner sought to operate an equestrian club in the U.S. offering training, stabling, event rentals, and educational programs to promote equestrian sport and contribute to community health and culture.

Prong 1 — national importancenot established · dispositive

“These letters, however, do not explain how the Petitioner's club would impact the field; the letters rely on the industry's anticipated growing role in the U.S. economy”

“the business plan depicts direct employment for ten individuals throughout the club's first five years of operation and the generation of $345,280 in payroll expenses”

“she has not provided a sufficient basis for her business projections, nor are the numbers corroborated by probative evidence”

“it is not clear how a business of the size and scope described would significantly impact the popularity of the sport in a certain region”

“The Petitioner has not demonstrated that her proposed endeavor has significant potential to employ U.S. workers or otherwise offer substantial positive economic effects for the nation.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “she has not provided a sufficient basis for her business projections, nor are the numbers corroborated by probative evidence”

  AAO decision text
• recommendation letter · discounted

  “these letters do not sufficiently demonstrate the national importance of the Petitioner's proposed endeavor”

  AAO decision text
• contract revenue · discounted

  “nor are the numbers corroborated by probative evidence sufficient to demonstrate that it is more likely than not that the business will have a substantial positive economic effect”

  AAO decision text

Where this case turned

• Business plan speculative · p1 — projections without a documented basis or steps
• 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

Notable

AAO reserved both the exceptional-ability threshold question and Dhanasar prongs 2 and 3 as unnecessary, dismissing solely on prong 1's national importance failure; notable emphasis on the disproportion between a small local business (10 employees) and the multi-billion-dollar national equine industry.

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. 204.5(k)(2)
• 8 C.F.R. 204.5(k)(3)(iii)
• Flores v. Garland
• Matter of L-A-C-
• USCIS Policy Manual F.5(B)(2)
• USCIS Policy Manual F.5(D)(1)

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