The Petitioner, pursuing a doctorate in educational administration while working part-time as a university admissions officer, proposed to implement a nationwide framework to improve teacher quality, early childhood education, and equitable learning opportunities through teacher training, university partnerships, AI-driven instructional feedback, and policy advocacy.

Prong 1 — national importanceestablished

“His proposed endeavor has substantial merit; and”

“The venture potentially has national importance.”

AAO decision text

Prong 2 — well positionednot established · dispositive

“the record lacks evidence of a record of success beyond simply being a competent professional in his field of endeavor.”

“he has not sufficiently explained how this "record of success" relates to his proposed endeavor.”

“the letters do not sufficiently relate his past achievements to his proposed endeavor.”

“None of the letters detail his proposed framework or discuss his positioning to implement it.”

“he has not sufficiently demonstrated how his publication and citation record relate to his proposed endeavor.”

“the Petitioner has not sufficiently explained how his teaching license or educational certifications relate to his proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the letters do not sufficiently relate his past achievements to his proposed endeavor.”

  AAO decision text
• citations publications · discounted

  “he has not sufficiently demonstrated how his publication and citation record relate to his proposed endeavor.”

  AAO decision text
• certification membership · discounted

  “the Petitioner has not sufficiently explained how his teaching license or educational certifications relate to his proposed endeavor.”

  AAO decision text
• business plan · discounted

  “he has demonstrated insufficient interest or support from relevant others”

  AAO decision text
• resume experience · discounted

  “he has not established sufficient similarities between his roles as an admissions officer and an implementer of a proposed national framework”

  AAO decision text

Where this case turned

• certification membership · p2 — certifications or memberships offered as proof of standing
• Citations insufficient · p2 — citation counts without qualitative account of impact
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• Letters not independent · p2 — letters come from employers and close collaborators, not independent experts
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

AAO partially credits the Petitioner's legal argument, finding SCOPS erred by imposing an EB-1-like 'frequent citation'/'widespread commentary' standard on his research (holding no such requirement exists under Dhanasar/USCIS policy for NIW), yet still affirms denial on other prong-2 grounds (failure to tie past achievements, letters, and certifications to the specific proposed endeavor). AAO also rejects Petitioner's pro se-leniency argument, holding no relaxed standard applies to unrepresented petitioners. Prong 3 expressly reserved under Bagamasbad.

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. 103.2(b)(8)

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