NIW Bearings
dismissedJUL222024_06B52032024-07-22 · appeal · Texas Service Center

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 nurse, proposed to work as a nurse in the United States providing high-quality urgent/emergency care and to train other nurses using techniques developed in Brazil.

Field: nursing · Read the decision (uscis.gov)

EB-2 threshold — addressed

AAO agreed Petitioner established she is an advanced degree professional based on bachelor's degree plus five years progressive experience and a credentials evaluation equating to a master's degree.

Prong 1 — national importancenot established · dispositive

the record does not suggest that the Petitioner intends to advance STEM technologies and research in the field of nursing.
none of the sources discuss her endeavor to work as a nurse, nor does her endeavor include solving or addressing the root causes of the nurse shortage
she has not provided sufficient evidence that her endeavor would solve the nurse shortage or that her endeavor would stand to provide substantial economic benefits in the United States.
the opinion does not focus on the impacts the Petitioner's nursing services will have on the national issues facing the field of nursing
this designation exempts U.S. employers of noncitizen nurses from having to test the labor market... it does not support a finding that nursing-related work inherently has national importance

AAO decision text

How the evidence was treated

  • business plan · discounted
    constitutes a material change in the petition, requiring the filing of a new petition
    AAO decision text
  • recommendation letter · discounted
    the letters are relevant to prong two of the Dhanasar framework but do not establish the broader implications
    AAO decision text
  • other · discounted
    they do not specifically discuss the Petitioner's proposed endeavor or explain how her endeavor would have broader implications
    AAO decision text
  • resume experience · discounted
    the Petitioner's past professional endeavors are the focus of Dhanasar's second prong
    AAO decision text
  • degree · credited

Where this case turned

  • Economic claims unsupported · p1job/revenue projections with no corroborating basis
  • Endeavor too vague · p1described as a job role, not a defined undertaking
  • Field importance conflated with endeavor · p1argues the field matters, not the specific endeavor
  • Occupational shortage argument rejected · p1argues a labor shortage — the labor-certification question, not Dhanasar
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Notable

AAO found the Director committed legal error by stating 'continuing employment in one's position, field, or industry is not an endeavor sufficient to evaluate under this analytical framework,' citing Love Korean Church v. Chertoff, but declined to remand because the outcome would be unchanged. AAO also rejected due process/standard-of-proof arguments raised by Petitioner and refused to consider a third, materially changed business plan (proposing an entrepreneurial venture employing 66 workers) submitted during RFE response, citing Matter of Izummi and Matter of Katigbak on material change requiring a new filing. Notes DOL's 'Schedule A' shortage designation for nurses does not itself establish national importance for NIW purposes.

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)
  • Flores v. Garland
  • Matter of E-M-
  • Matter of Ho
  • Matter of Izummi
  • Matter of Katigbak
  • Matter of L-A-C-

What this case teaches

Analyst reading of the decision text.

Decisive factor

Evidence and expert letters addressed the importance of nursing generally and petitioner's personal skills/experience, not the specific endeavor's broader national-level impact, failing prong one.

Transferable lesson

Tie industry-wide statistics and expert opinions explicitly to the petitioner's specific proposed endeavor's prospective impact, not just field importance or personal credentials.

Endeavor framing

vague

National-importance theory

public_health · economic_job_creation · us_competitiveness · national_security · geographic_or_shortage_area · stem_positive_factor

Evidence targeting

person_focused

Cases in adjacent profiles