Kapoor v. United States Citizenship and Immigration Services

CourtDistrict Court, E.D. New York
DecidedJanuary 21, 2025
Docket2:22-cv-07135
StatusUnknown

This text of Kapoor v. United States Citizenship and Immigration Services (Kapoor v. United States Citizenship and Immigration Services) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kapoor v. United States Citizenship and Immigration Services, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------X ROHAN KAPOOR,

Plaintiff, MEMORANDUM & ORDER 22-cv-7135(JS) -against-

UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, et al.,

Defendants. --------------------------------X

APPEARANCES

For Plaintiff: Rohan Kapoor 529 Nolting Avenue North Babylon, NY 11703 Pro Se

For Defendants: David Allen Cooper, Esq. United States Attorney’s Office Eastern District of New York 271-A Cadman Plaza East, 7th Floor Brooklyn, NY 11201

Nairi Simonian Gruzenski, Esq. DOJ-USAO Eastern District of New York 271-A Cadman Plaza East Brooklyn, NY 11201

SEYBERT, District Judge: Plaintiff Rohan Kapoor (“Plaintiff” or “Mr. Kapoor”) commenced this action against the United States Citizenship and Immigration Services (“USCIS”) and Ur M. Jaddou, in her official capacity as the Director of USCIS (“Ms. Jaddou”) (collectively, “Defendants” or “the Government”), on November 22, 2022, seeking review of USCIS’s decision to deny Mr. Kapoor an “extraordinary ability” visa. (See generally, Compl., ECF No. 1.) Mr. Kapoor filed a first amended complaint (“AC”) on September 14, 2023. (See

generally, AC, ECF No. 21.) Mr. Kapoor filed a second amended complaint (“SAC”) on February 23, 2024. (See generally, SAC, ECF No. 35.) The Government filed a motion to dismiss for failure to state a claim, or in the alternative, a motion for summary judgment (“Gov’ts Motion” or “MSJ”), on July 8, 2024. (See generally, MSJ, ECF No. 40.) For the reasons stated herein, the Government’s Motion is GRANTED. BACKGROUND I. Statutory and Regulatory Background Congress created five “preference” categories for employment-based visas in the Immigration Act of 1990, Pub. L. No. 101-649 (1990). See 8 U.S.C. § 1153(b).

“First preference” visas carry multiple advantages. See Jafarov v. U.S. Citizenship & Immigr. Servs., No. 23 CIV. 3372, 2024 WL 69056, at *1 (S.D.N.Y. Jan. 5, 2024). First, if a noncitizen1 qualifies for a “first preference” visa, that person need not have an offer of employment in the United States. 8 C.F.R. § 204.5(h)(5) (“Neither an offer for employment in the United

1 This decision uses the term “noncitizen” as the equivalent to the statutory term “alien” that is used within the meaning of the Immigration and Nationality Act. This follows the Supreme Court’s lead. See, e.g., Nasrallah v. Barr, 590 U.S. 573, 578 n.2 (2020). States nor a labor certification [from the Department of Labor] is required for this classification.”). Second, recipients of “first preference” visas do not have to go through the “time-consuming

labor certification process” that other visa applicants must go through. Jafarov, 2024 WL 69056, at *1 (quoting Kazarian v. U.S. Citizenship & Immigr. Servs., 596 F.3d 1115, 1120 (9th Cir. 2010)). Finally, there is not a long backlog for these visas, so first preference visa recipients are able to “avoid the years-long waiting periods that apply to most other employment-based immigration categories.” Id. (quoting Amin v. Mayorkas, 24 F.4th 383, 387 (5th Cir. 2022)). One of the types of “first preference” visas is for noncitizens of “extraordinary ability,” “colloquially dubbed as the ‘Einsten’ or ‘genius’ visa.” Id. (quoting Amin, 24 F.4th at 386-87). Noncitizens seeking to obtain this type of visa bear the

burden of demonstrating the following three criteria: (i) the alien has extraordinary ability in the sciences, arts, education, business, or athletics which has been demonstrated by sustained national or international acclaim and whose achievements have been recognized in the field through extensive documentation,

(ii) the alien seeks to enter the United States to continue work in the area of extraordinary ability, and

(iii) the alien's entry into the United States will substantially benefit prospectively the United States.

8 U.S.C. § 1153(b)(1)(A)(i)–(iii). “Extraordinary ability” requires “a level of expertise indicating that the individual is one of that small percentage who have risen to the very top of the field of endeavor.” 8 C.F.R. § 204.5(h)(2). USCIS reviews applications for the “extraordinary

ability” visas through a two-step process. See Jafarov, 2024 WL 69056, at *1 (first citing U.S. CITIZENSHIP & IMMIGR. SERVS., POLICY MANUAL vol. 6, pt. F, ch. 2 (2023) [hereinafter, “POLICY MANUAL”]; then citing Amin, 24 F.4th at 388–89). The first step of USCIS’s adjudication process (the “First Step”) requires the applicant to provide “initial evidence” of either: (1) a major “one-time achievement,” such as a Nobel Prize, or (2) at least three of the following criteria: (i) Documentation of the alien's receipt of lesser nationally or internationally recognized prizes or awards for excellence in the field of endeavor;

(ii) 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 fields;

(iii) Published material about the alien in professional or major trade publications or other major media, relating to the alien's work in the field for which classification is sought. Such evidence shall include the title, date, and author of the material, and any necessary translation;

(iv) Evidence of the alien's participation, either individually or on a panel, as a judge of the work of others in the same or an allied field of specification for which classification is sought;

(v) Evidence of the alien's original scientific, scholarly, artistic, athletic, or business-related contributions of major significance in the field; (vi) Evidence of the alien's authorship of scholarly articles in the field, in professional or major trade publications or other major media;

(vii) Evidence of the display of the alien's work in the field at artistic exhibitions or showcases;

(viii) Evidence that the alien has performed in a leading or critical role for organizations or establishments that have a distinguished reputation;

(ix) Evidence that the alien has commanded a high salary or other significantly high remuneration for services, in relation to others in the field; or

(x) Evidence of commercial successes in the performing arts, as shown by box office receipts or record, cassette, compact disk, or video sales.

8 C.F.R. § 204.5(h)(3)(i)–(x). If USCIS finds the petitioner proved by a preponderance of the evidence that he or she satisfies the above First Step criteria, then USCIS “moves on to step two, a totality of the circumstances inquiry, to make its final determination of a petition’s merits.” Cuckic v. Jaddou, No. 21-CV-8395, 2023 WL 2586031, at *2 (S.D.N.Y. Mar. 21, 2023) (citing Noroozi v. Napolitano, 905 F. Supp. 2d 535, 539 (S.D.N.Y. 2012)).

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