NIW Bearings
remandedMAY212024_02B52032024-05-21 · 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 customs and trade specialist, proposed to form and operate a U.S. consultancy company offering customs and trade advisory services to help client companies improve efficiency, productivity, and profitability.

Field: customs and trade consultancy · Read the decision (uscis.gov)

EB-2 threshold — not met

AAO found the Director erroneously credited a nonexistent bachelor's degree and that the Petitioner failed to show her foreign degrees were equivalent to a U.S. bachelor's degree or that she had five years of progressive post-degree experience.

Prong 1 — national importanceestablished

Prong 2 — well positionedestablished

Prong 3 — balance of factorsestablished

How the evidence was treated

  • degree · discounted
    she did not provide evidence showing either her master degree or bachelor degree is the foreign equivalent above that of a U.S. bachelor's degree
    AAO decision text
  • resume experience · discounted
    the letter is insufficient to show she has five years of progressive experience
    AAO decision text
  • recommendation letter · ignored
    The decision does not identify or analyze the Petitioner's submitted evidence and does not explain the basis for this determination.
    AAO decision text
  • business plan · ignored
    The decision does not identify or analyze the Petitioner's submitted evidence and does not explain the basis for this determination.
    AAO decision text
  • certification membership · ignored

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Notable

AAO remanded largely due to Director's factual error—crediting a nonexistent 'bachelor of science in industrial engineering' degree not present in the record—and due to the Director's conclusory, unexplained findings on all three Dhanasar prongs, which prevented meaningful appellate review. AAO expressly declined to opine on the ultimate outcome.

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. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(ii)
  • 8 C.F.R. 204.5(k)(3)(iii)
  • Flores v. Garland
  • Kazarian v. USCIS
  • USCIS Policy Manual F.5(B)(2)
  • Visinscaia v. Beers

What this case teaches

Analyst reading of the decision text.

Decisive factor

Director's decision was procedurally deficient—conclusory, unexplained findings on underlying classification and all three Dhanasar prongs prevented meaningful appellate review, requiring remand rather than merits resolution.

Transferable lesson

Ensure adjudicators (and petitioners) build a fully reasoned record on each prong; unexplained conclusions on eligibility or Dhanasar prongs invite remand regardless of ultimate merits.

Endeavor framing

vague

National-importance theory

economic_growth_generic

Evidence targeting

mixed

Cases in adjacent profiles