The Petitioner, an architect and business administrator, proposed to establish a consulting firm to mitigate the U.S. affordable housing crisis through design, planning, and financial advisory services for housing developers, nonprofits, and universities.

Prong 1 — national importancenot established · dispositive

“they found the endeavor was too vague and that the evidence did not show how the impact of the Petitioner's work would sufficiently extend beyond her company and its clients to impact the field or industry more broadly.”

“the record does not illustrate how her specific endeavor would sufficiently extend beyond her company and clients to impact the industry, region, or nation more broadly.”

“she did not establish the significance of this data to show that the benefits to the regional or national economy would reach the level of "substantial positive economic effects" contemplated by Dhanasar.”

“A petitioner's work in an important industry, even one that is the subject of federal priorities, is not sufficient, in and of itself, to establish the national importance of the proposed endeavor.”

“many of the letters do reference the Petitioner's proposed endeavor, they are largely conclusory in nature and do not provide a sufficient evidentiary basis for their claims.”

“she presented little supporting evidence corroborating the assertions and figures in her plan.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “they are largely conclusory in nature and do not provide a sufficient evidentiary basis for their claims.”

  AAO decision text
• business plan · discounted

  “she presented little supporting evidence corroborating the assertions and figures in her plan.”

  AAO decision text
• other · discounted

  “it does not sufficiently demonstrate with specificity how the Petitioner's work would impact these areas to show its national importance.”

  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
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• 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

The Petitioner raised an abuse-of-discretion argument under Buletini v. INS, claiming SCOPS failed to consider the totality of the evidence; AAO rejected this, citing several circuit court cases (Amin, Martinez, Pakasi, Kazemzadeh, Teixeira) for the proposition that agencies need not address every piece of evidence individually. AAO also emphasized that the petitioner conflated the value of the affordable-housing field generally with the specific national importance of her individual endeavor.

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
• Buletini v. INS
• Flores v. Garland

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