NIW Bearings
dismissedAPR252025_04B52032025-04-25 · appeal

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 paralegal with legal experience in Venezuela and the United States, sought EB-2 classification as an individual of exceptional ability along with a national interest waiver, though the specifics of his proposed endeavor were not reached.

Field: legal services/paralegal · Read the decision (uscis.gov)

EB-2 threshold — not met

Petitioner did not qualify as an advanced degree professional (paralegal occupation does not meet 'profession' definition, waived on appeal) nor as an individual of exceptional ability, having established only two of the required three criteria (degree and membership), failing to establish ten years of full-time experience or recognition of achievements/significant contributions to the industry.

How the evidence was treated

  • resume experience · discounted
    these documents do not provide the dates of his employment, whether he worked on a full-time basis, or the duties of his positions
    AAO decision text
  • recommendation letter · discounted
    they do not list his duties in his various positions, state if he worked full-time, or discuss the duration of his employment
    AAO decision text
  • certification membership · credited
  • degree · credited
  • other · discounted
    it is unclear who authored the reviews, who the reviews are about, and when the reviews were written
    AAO decision text

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Notable

The AAO did not reach any Dhanasar prong analysis because the petitioner failed the threshold EB-2 exceptional ability classification; the AAO explicitly reserved opinion on prongs one and three despite Petitioner's appellate arguments, citing INS v. Bagamasbad to avoid advisory findings. Case turned entirely on whether experience letters/comparable evidence satisfied 8 C.F.R. 204.5(k)(3)(ii)(B).

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(g)(1)
  • 8 C.F.R. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(iii)
  • Flores v. Garland
  • Matter of Ho
  • Matter of O-R-E-
  • Matter of R-A-M-
  • USCIS Policy Manual F.5(B)(2)

What this case teaches

Analyst reading of the decision text.

Decisive factor

Petitioner failed to establish EB-2 classification as individual of exceptional ability, meeting only 2 of 6 required criteria; comparable evidence for 10-years'-experience criterion lacked required duty descriptions, dates, and full-time status confirmation.

Transferable lesson

Secure proper regulatory-compliant employer letters (duties, dates, full-time status) before relying on comparable evidence; threshold EB-2 eligibility must be solid before any NIW/Dhanasar argument is reached.

Endeavor framing

vague

Evidence targeting

person_focused

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