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Thread: Article: Will Kazarian Change The 0-1 Visa? By Gary Endelman and Cyrus D. Mehta

  1. #1

    Article: Will Kazarian Change The 0-1 Visa? By Gary Endelman and Cyrus D. Mehta



    value of the O-1 visa is its flexibility, an adaptive quality
    that enables it to respond to the different needs of different
    petitioners. Any formulaic approach that restricts the full and
    open expression of such subtlety not only reduces the value of
    the O-1 but undermines its bedrock utility. That is why the
    stated willingness of the USCIS to apply a subjective

    "font-family: Arial, Helvetica, sans-serif;">Kazarian-style
    final merits analysis in the O-1 context, even after the
    applicant has satisfied the evidentiary criteria, should arouse
    our most serious concern. This is true for several reasons. Not
    only does such a constricted view of the O-1 prevent it from
    being all that it can be, but it blurs the distinction between
    the O-1 and the EB1-1 extraordinary ability immigrant petition,
    two different visa categories with different purposes. Just as
    the approval of an O-1 nonimmigrant petition does not ensure
    similar approval of an EB1-1 immigrant petition, the analytical
    tools used by USCIS examiners to evaluate the merits of these
    distinct categories must themselves remain separate.

    "font-family: Arial, Helvetica, sans-serif;">With this as our
    starting point, what do the regulations tell us about the O-1?
    The O-1 visa is a useful visa for people, under INA
    §101(a)(15)(o), who can demonstrate extraordinary ability in
    the sciences, arts, education, business or athletics. Unlike the
    H-1B visa, it is not subject to an annual cap. It can also be
    availed of by artists and entertainers, people who are
    traditionally self-employed, as long as an agent serves as a
    sponsor. Although the “extraordinary ability”
    standard is a high one, artists can prove their eligibility under
    a lower “distinction” standard pursuant to INA
    §101(a)(46). Those qualifying for an O-1 visa in the motion
    pictures or television industry have to demonstrate extraordinary
    achievement, rather than extraordinary ability. There are thus
    three different standards under the O-1 visa.

    "font-family: Arial, Helvetica, sans-serif;">Extraordinary
    ability in science, education, business or athletics means
    “a level of expertise indicating that the person is one of
    the small percentages who have arisen to the very top of the
    field of endeavor.” 8 CFR 214.2(o)(3)(ii).

    "font-family: Arial, Helvetica, sans-serif;">The extraordinary
    criteria, as set forth in 8 CFR 214.2(o)(iii), are as

    "font-family: Arial, Helvetica, sans-serif;">(A) Receipt of a
    major, internationally recognized award, such as the Nobel Prize;

    "font-family: Arial, Helvetica, sans-serif;">(B) At least three
    of the following forms of documentation:

    "font-family: Arial, Helvetica, sans-serif;">(1) Documentation of
    the alien's receipt of nationally or internationally recognized
    prizes or awards for excellence in the field of

    "font-family: Arial, Helvetica, sans-serif;">(2) Documentation of
    the alien's membership in associations in the field for which
    classification is sought, which require outstanding achievements
    of their members, as judged by recognized national or
    international experts in their disciplines or

    "font-family: Arial, Helvetica, sans-serif;">(3) Published
    material in professional or major trade publications or major
    media about the alien, relating to the alien's work in the field
    for which classification is sought, which shall include the
    title, date, and author of such published material, and any
    necessary translation;

    "font-family: Arial, Helvetica, sans-serif;">(4) Evidence of the
    alien's participation on a panel, or individually, as a judge of
    the work of others in the same or in an allied field of
    specialization to that for which classification is

    "font-family: Arial, Helvetica, sans-serif;">(5) Evidence of the
    alien's original scientific, scholarly, or business-related
    contributions of major significance in the field;

    "font-family: Arial, Helvetica, sans-serif;">(6) Evidence of the
    alien's authorship of scholarly articles in the field, in
    professional journals, or other major media.

    "font-family: Arial, Helvetica, sans-serif;">(7) Evidence that
    the alien has been employed in a critical or essential capacity
    for organizations and establishments that have a distinguished

    "font-family: Arial, Helvetica, sans-serif;">(8) Evidence that
    the alien has either commanded a high salary or will command a
    high salary or other remuneration for services, evidenced by
    contracts or other reliable evidence.

    "font-family: Arial, Helvetica, sans-serif;">(C) If the criteria
    in paragraph (o)(3)(iii) of this section do not readily apply to
    the beneficiary's occupation, the petitioner may submit
    comparable evidence in order to establish the beneficiary's

    "font-family: Arial, Helvetica, sans-serif;">Extraordinary
    Achievement in the motion pictures and television means a
    “very high level of accomplishment in the motion picture or
    TV industry evidenced by a degree of skill and recognition
    significantly above that ordinarily encountered.” 8 CFR

    "font-family: Arial, Helvetica, sans-serif;">As already noted, an
    O-1 in the arts has to prove only distinction. While
    “extraordinary achievement” and
    “distinction” may appear to be two separate
    standards, the criteria for demonstrating extraordinary
    achievement in the motion picture or TV industry or distinction
    in the arts are almost identical, and set forth at 8 CFR
    214.2(o)(3)(iv) and (v), which are as follows:

    "font-family: Arial, Helvetica, sans-serif;">(A) Evidence that
    the alien has been nominated for, or has been the recipient of,
    significant national or international awards or prizes in the
    particular field such as an Academy Award, an Emmy, a Grammy, or
    a Director's Guild Award; or

    "font-family: Arial, Helvetica, sans-serif;">(B) At least three
    of the following forms of documentation:

    "font-family: Arial, Helvetica, sans-serif;">(1) Evidence that
    the alien has performed, and will perform, services as a lead or
    starring participant in productions or events which have a
    distinguished reputation as evidenced by critical reviews,
    advertisements, publicity releases, publications contracts, or

    "font-family: Arial, Helvetica, sans-serif;">(2) Evidence that
    the alien has achieved national or international recognition for
    achievements evidenced by critical reviews or other published
    materials by or about the individual in major newspapers, trade
    journals, magazines, or other publications;

    "font-family: Arial, Helvetica, sans-serif;">(3) Evidence that
    the alien has performed, and will perform, in a lead, starring,
    or critical role for organizations and establishments that have a
    distinguished reputation evidenced by articles in newspapers,
    trade journals, publications, or testimonials;

    "font-family: Arial, Helvetica, sans-serif;">(4) Evidence that
    the alien has a record of major commercial or critically
    acclaimed successes as evidenced by such indicators as title,
    rating, standing in the field, box office receipts, motion
    pictures or television ratings, and other occupational
    achievements reported in trade journals, major newspapers, or
    other publications;

    "font-family: Arial, Helvetica, sans-serif;">(5) Evidence that
    the alien has received significant recognition for achievements
    from organizations, critics, government agencies, or other
    recognized experts in the field in which the alien is engaged.
    Such testimonials must be in a form which clearly indicates the
    author's authority, expertise, and knowledge of the alien's
    achievements; or

    "font-family: Arial, Helvetica, sans-serif;">(6) Evidence that
    the alien has either commanded a high salary or will command a
    high salary or other substantial remuneration for services in
    relation to others in the field, as evidenced by contracts or
    other reliable evidence; or

    "font-family: Arial, Helvetica, sans-serif;">If the above
    criteria do not readily apply, only those establishing
    distinction in the arts can submit comparable evidence. People
    trying to qualify for an O-1 visa under the extraordinary
    achievement standard for motion pictures and the TV industry
    cannot submit comparable evidence.

    "font-family: Arial, Helvetica, sans-serif;">All O-1 petitions
    must be accompanied by consultations from the appropriate unions,
    and if they do not exist, may contain opinions from expert

    "font-family: Arial, Helvetica, sans-serif;">Recent unpublished
    decisions from the Appeals Administrative Office are applying the
    two-part approach in
    "font-family: Arial, Helvetica, sans-serif;"> ""
    target="_blank">Kazarian v. USCIS
    "font-family: Arial, Helvetica, sans-serif;">, 596 F.3d 1115 (9th
    Cir. 2010). When
    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    first decided, it was received with much jubilation as it was
    thought that the standards for establishing extraordinary ability
    under a green card category pursuant to INA §
    203(b)(1)(A)(i) would be more straightforward and
    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    "font-family: Arial, Helvetica, sans-serif;">essentially holds
    that a petitioner claiming extraordinary ability need not submit
    extraordinary evidence to prove that he or she is a person of
    extraordinary ability. If one of the evidentiary criteria
    requires a showing of scholarly publications, the petitioner need
    not establish that the scholarly publications in themselves are
    also extraordinary in order to qualify as a person of
    extraordinary ability. This is a circular argument, which

    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    "font-family: Arial, Helvetica, sans-serif;">appropriately shot
    down. If
    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    stopped there, it would have been a wonderful outcome.
    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    has been
    interpreted to also require a vague and second step analysis
    known as the “final merits determination,” which can
    stump even the most extraordinary. We point readers to Cyrus
    Mehta’s blog,
    style="font-family: Arial, Helvetica, sans-serif;" target=
    "_blank">How Extraordinary Does One Have to Be to Qualify as a
    Person of Extraordinary Ability
    "font-family: Arial, Helvetica, sans-serif;">, for a detailed
    analysis of the
    "font-family: Arial, Helvetica, sans-serif;">Kazarian
    and how the USICS has interpreted it.

    "font-family: Arial, Helvetica, sans-serif;">In its December 22,
    2010 Policy Memorandum, (" ""
    target="_blank">Policy Memorandum
    "), United States Citizen
    and Immigration Services (USCIS) implemented a "two-part
    adjudicative approach" for extraordinary ability, outstanding
    researcher and professor, and exceptional ability immigrant visa
    petitions. Here is the first, but unfortunately not the last,
    indication of a desire by the USCIS to utilize the final merits
    methodology of Kazarian in case types not mentioned in or
    justified by Kazarian itself. While the USCIS doubtless
    may view the extension of Kazarian to the O-1 as a logical
    expansion of its prior application to EB1-(2) outstanding
    researcher and EB-2 exceptional ability cases, skeptics may
    properly question whether this ever-widening deployment signifies
    not a greater precision but a lack of programmatic restraint.
    The Service cites Kazarian as the basis for modifying the
    Adjudicator's Field Manual to include a second step in the
    adjudication process, the "final merits determination." Although
    Kazarian did not actually create a “final merits
    determination,” and objected essentially to the AAO’s
    imposition of extra requirements under the evidentiary criteria
    in 8 CFR §§ 204.5(h)(3)(iv) and (v), the Service seized
    on the following excerpts in Kazarian as a basis for
    justifying a “final merits determination”

    "font-family: Arial, Helvetica, sans-serif;">(1) While other
    authors' citations (or lack thereof) might be relevant to the
    final merits determination of whether a petitioner is at
    the very top of his or her field of endeavor, they are not
    relevant to the antecedent procedural question of whether the
    petitioner has provided at least three types of evidence
    (emphasis added); and

    "font-family: Arial, Helvetica, sans-serif;">(2) ... [W]hile the
    AAO's analysis might be relevant to a final merits
    the AAO may not unilaterally impose a novel
    evidentiary requirement (emphasis added).

    "font-family: Arial, Helvetica, sans-serif;">Kazarian v.
    , 596 F.3d at 1121.

    "font-family: Arial, Helvetica, sans-serif;">Under this two part
    test as it applies to an EB-1(1) extraordinary ability petition,
    the USCIS must essentially accept the evidence of extraordinary
    ability under the 10 criteria set forth in 8 CFR
    §204.5(h)(3)(i)-(x). The USCIS cannot object to the
    submission of the alien’s “scholarly articles in the
    field, in professional or major trade publications or other major
    media” under §204.5(h)(vi) unless there is
    consideration of the research community’s reaction to those
    articles, as it did erroneously in Kazarian. Still, the
    USICS may take this extra evidentiary factor into consideration,
    namely, the lack of reaction in the research community, during
    the “final merits determination” analysis. It is
    readily apparent that the analysis under the second step defeats
    the very essence of the holding in Kazarian that the USCIS
    cannot impose extra requirements under the evidentiary criteria.
    What it cannot do under the first step, the USCIS can still do
    under the “final merits determination.”

    "font-family: Arial, Helvetica, sans-serif;">The authors question
    whether it is appropriate for the AAO to adopt the
    Kazarian two step analysis to O-1 petitions.
    Kazarian involved an extraordinary ability petition under
    INA § 203(b) (1)(A)(i), which is the employment-based first
    preference category (EB-1), through which an alien obtains lawful
    permanent residence. While the extraordinary ability criteria
    under the EB-1 may be identical to the O-1 extraordinary criteria
    for science, education, business and athletics, the criteria for
    extraordinary achievement in the motion picture and TV industry
    and for distinction in the arts are markedly different. Moreover,
    the O-1 visa petition requires a consultation from a union or
    expert opinion. A favorable opinion from the relevant union for
    an artist ought to be given deference by the USICS. Injecting
    Kazarian into the O-1 visa adds needless subjectivity into
    the decision making process.

    "font-family: Arial, Helvetica, sans-serif;">Kazarian’
    two-part test and final merits determination analysis runs
    counter to prior decisions such as, Buletini v. INS, 860
    F.Supp. 1222 (E.D. Mich 1994), which held, "[o]nce it is
    established that the alien's evidence is sufficient to meet three
    of the criteria listed in 8 C.F.R. § 204.5(h)(3), the alien
    must be deemed to have extraordinary ability unless the INS sets
    forth specific and substantiated reasons for its finding that the
    alien does not meet extraordinary ability.” Id. at 1234.
    Similarly, in Muni v. INS, 891 F. Supp. 440 (N.D. Ill.
    1995), a federal court reversed a denial for a professional
    hockey player where INS did not apply the proper criteria for
    extraordinary ability, and based its decision on the ground that
    he was not an all-star or one of the highest paid players. Under
    the burden shifting approach in Buletini, the petitioner
    should be deemed qualified, and the burden then shifts onto the
    Service to reject the evidence that meet the criteria, if
    suppose, it finds that the evidence was fraudulent or too dated
    and stale. In fact, such a burden shifting approach is not
    unknown in other aspects of immigration law. If the
    Kazarian final merits determination analysis was deployed
    at that time, both Muni and Buletini, a leading physician
    in Albania, may have suffered a different fate. As our colleague
    David Isaacson has pointed out, in the asylum context, an
    applicant who demonstrates that he or she has suffered past
    persecution on account of a protected ground is rebuttably
    presumed to have a reasonable fear of future persecution on that
    same ground. 8 C.F.R. §§ 208.13(b)(1), 1208.13(b)(1).
    In such cases, by regulation, “the Service shall bear the
    burden of establishing by a preponderance of the evidence”
    that a change in circumstances, or the reasonable possibility of
    relocating within the country of persecution, should lead to a
    denial of asylum. 8 C.F.R. §§ 208.13(b)(1)(ii),

    "font-family: Arial, Helvetica, sans-serif;">Moreover the USCIS
    Policy Memorandum, which invented this two-part test from its
    interpretation of Kazarian, does not indicate that it
    would apply this test to O-1 visa adjudications, even though it
    has extended the two-art test to outstanding professors and
    researchers and aliens of exceptional ability. On the other
    hand, the ""
    target="_blank">USCIS Adjudicator’s Field Manual (AFM)
    section on O-1s ( 33. 4(d))
    states, as follows:

    "font-family: Arial, Helvetica, sans-serif;">For an O-1 or O-2
    case, the adjudicator must determine whether the alien meets the
    standards as outlined in the regulations cited above; however,
    he/she cannot make a favorable determination simply because the
    petitioner has submitted three of the forms of documentation
    mentioned. It must be a decision based on whether the total
    evidence submitted establishes that the alien of extraordinary
    ability has sustained national or international acclaim and
    recognition in his field of endeavor; or in the case of an alien
    of extraordinary ability in the arts and extraordinary
    achievement in the motion picture or television industry, whether
    he or she has a demonstrated record of high level accomplishment
    or a high level of achievement (or "distinction").

    "font-family: Arial, Helvetica, sans-serif;">However, it is not
    clear from this passage whether the USCIS intended to
    specifically apply the Kazarian “final merits
    determination” approach. The USCIS, and the predecessor
    Immigration and Naturalization Service, has always insisted that
    the alien overall meet the standard of extraordinary ability, but
    this was never meant to be as expansive as the Kazarian
    final merits determination. Rather, under the Buletini
    standard, the burden was on the government to the INS sets forth
    specific and substantiated reasons for its finding that the alien
    does not meet extraordinary ability.

    "font-family: Arial, Helvetica, sans-serif;">The positive aspect
    of Kazarian, which established that the USCIS cannot
    create extra-regulatory criteria during the adjudication of a
    visa petition, without formally amending the regulation through
    notice and comment to stakeholders, ought to be applicable to all
    visa petitions. On the other hand, introducing the vague and
    subjective “final merits determination” to O-1 visas
    will needlessly add subjectivity to the process, when Congress
    specifically required that O-1 visa petitions be accompanied by
    union consultations and expert opinions. Kazarian was also
    a decision that deals with the extraordinary criteria under the
    EB-1, while the O-1 visa has three different standards –
    extraordinary ability, extraordinary achievement and distinction.
    The guidance fails to alert USCIS adjudicators on how they could
    specifically apply the “final merits determination”
    standard to extraordinary achievement and distinction. It is
    also important to restrict the application of the Kazarian
    final merits determination to other visa adjudications, or else
    there will be no limitation to the reach of the final merits
    determination. Will is also impact H-1B and L visa adjudications?
    The long-range impact of what charitably be called
    “doctrine creep” is not hard to fathom. If the USCIS
    were to use the Kazarian final merits exercise much as it
    now deploys the ",0113-h1b.pdf"
    target="_blank">Neufeld Memo
    , the meaning of
    “extraordinary ability” would be transformed beyond
    all ready recognition, much as the right of control has evolved
    beyond the imagination of the regulation that created it. When
    Congress enacted the standards for visa petitions, it intended
    adjudicators to faithfully apply those standards to either
    approve or deny the petitions. The infusion of the
    Kazarian “final merits determination” to visa
    adjudications would allow USCIS adjudicators to impermissibly
    stray from those standards.

    "font-family: Arial, Helvetica, sans-serif;">Beyond that, to wrap
    the O-1 in an analytical straitjacket is yet another disturbing
    example of legislation through interpretation by the USCIS. While
    the INA itself does not change, what it means most certainly does
    change. All this comes about without the assent of Congress,
    whether expressed or implied, and in the absence of any notice
    and comment rulemaking mandated by the Administrative Procedures
    Act, thus eliminating the possibility of participation by
    concerned stakeholders. We all remember how the Administrative
    Appeals Unit decision in the "" target=
    "_blank">New York State Department of Transportation case

    completely changed the meaning and practice of the National
    Interest Waiver. More recently, the USCIS jihad against the L-1B
    visa category and what amounts to a de facto rejection of the
    very concept of specialized knowledge has, in practice, repealed
    this visa provision to a very large extent. Is the O-1 now to
    suffer the same fate? What may be the most hard to detect damage
    resulting from invoking Kazarian in the O-1 arena is the
    fact that the evidence submitted by an O-1 petitioner is now to
    be judged by criteria that cannot be defined or even anticipated
    in advance Any attempt by the USCIS to use Kazarian to
    complicate the O-1 must be resisted. Complexity that exists for
    its own sake, not as an aid to an intellectually honest
    assessment but as a substitute for it does not advance the
    national interest. In a democratic society, the logic of any
    successful national policy must be transparently obvious to those
    who have to obey and support it. That is why the blurring of
    distinction between the O-1 and the Kazarian final merits
    determination is not only of little benefit to its intended
    beneficiaries, but actually frustrates any coherent attempt to
    make the system more amenable to consistent interpretation and
    effective enforcement.

    This article was originally published on on April 28, 2014. Reprinted with permission.

    About The Author

    Gary EndelmanGary Endelman is the Senior Counsel at FosterQuan, LLP in Houston, TX. His practice includes I-9 compliance and audits, E-Verify compliance, immigration issues related to mergers and acquisitions, employment-based nonimmigrant visas, B-1 OCS, permanent residence petitions for ability, outstanding researchers, PERM labor certification; naturalization, derivation and transmission of U.S. citizenship. Mr. Endelman graduated with a B.A. in History from the University of Virginia, a Ph.D. in United States History from the University of Delaware, and a J.D. from the University of Houston. From 1985 to 1995, he worked at one of the largest immigration firms in the country. From 1995 to 2011, he worked as the in-house immigration counsel for BP America Inc., a multinational energy company ranked as one of the top 5 largest companies in the world. Mr. Endelman is board certified in Immigration and Nationality Law by the State Bar of Texas, Board of Legal Specialization and Chair of the Examinations Committee in Immigration and Nationality Law for the Texas Board of Legal Specialization. He is a frequent national speaker and writer on immigration related topics including several columns and blogs on immigration law. He served as a senior editor of the national conference handbook published by AILA for ten years. In July 2005, Mr. Endelman testified before the United States Senate Judiciary Committee on comprehensive immigration reform. Please contact Gary Endelman at The views expressed by Mr. Endelman in this article are his personally and not those of FosterQuan, LLP.

    Cyrus D. MehtaCyrus D. Mehta, a graduate of Cambridge University and Columbia Law School, is the Managing Member of Cyrus D. Mehta & Associates, PLLC in New York City. He is the current Chair of AILA's Ethics Committee and former Chair of AILA's Pro Bono Committee. He is also the former Chair of the Board of Trustees of the American Immigration Council (2004-06) and Chair of the Committee on Immigration and Nationality Law (2000-03) of the New York City Bar Association. He is a frequent speaker and writer on various immigration-related issues, including on administrative remedies and ethics, and is also an adjunct associate professor of Law at Brooklyn Law School, where he teaches a course entitled "Immigration and Work." Mr. Mehta received the AILA 2011 Michael Maggio Memorial Award for his outstanding efforts in providing pro bono representation in the immigration field.

    The opinions expressed in this article do not necessarily reflect the opinion of

  2. #2
    It is not only the O-1 visa which may be about to become an endangered species. The above article also refers to the 2010 Neufeld memo, which sought to restrict access to H-1B visas by unreasonably narrowing the definition of the employer-employee relationship.

    H-1B is now under attack from another direction (besides the lack of visas), namely the latest USCIS theory that there must be a one-to-one correspondence (or very close to it) between a given position and the number of bachelor degree fields of study which are related to the position.

    According to this theory, which was vigorously struck down by a federal district court in the 2012 decision Residential Finance Corporation v. USCIS, if there are more than one, or at most perhaps two or three, fields of study which the OOH regards as related to the position in question, that is the same as saying that every college bachelor degree major is sufficient preparation for the position and it is therefore not an H-1B specialty occupation.

    If USCIS adjudicators continue to follow this twisted logic, there may soon be very few H-1B specialty occupations left, as I have been pointing out in my recent "blogging" posts regarding Market Research Analysts. It is also interesting to note how eager USCIS is to embrace a federal court decision, such as the 9th Circuit Kazarian case described in the above article, whenever there appears to be a way that it can be used to limit access to a particular visa category.

    However, when a federal court decision (admittedly only at the district court level, as in Residential Finance Corporation), is unambiguously in favor of the petitioner, that decision turns out to have a way of falling into the USCIS' "memory hole" (as described in Orwell's famous novel "1984"). None of the Service Center RFE's I have seen using the above argument anywhere mentions the Residential Finance Corporation decision.

    There are already more than enough problems for immigration coming from FAIR, CIS, NumbersUSA, Tea Party, and their supporters in Congress. But is USCIS itself being taken over by anti-immigrant ideologues, pushing a radical restrictionist agenda through "interpretation"? This is a question worth asking.

    Roger Algase
    Attorney at Law
    Last edited by ImmigrationLawBlogs; 04-30-2014 at 08:16 AM.

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