Aravamuthan v. US Citizenship & Immigration Service
3:23-cv-01412
| N.D. Tex. | Jun 17, 2025Background
- Plaintiff Srikanth Aravamuthan, an Indian citizen, filed for an EB-1 "extraordinary ability" visa with USCIS, asserting he is an international leader in business and management consulting.
- Aravamuthan previously held O-1 status and filed multiple I-140 petitions; the one at issue in this case is his second EB-1 petition, which was denied by USCIS in November 2023 after reopening and review.
- Aravamuthan sought judicial review in the Northern District of Texas, arguing the denial was arbitrary and capricious under the Administrative Procedure Act (APA).
- The case comes before the court on cross-motions for summary judgment by Aravamuthan and the defendants, USCIS and its Director.
- The legal standard applied is whether USCIS’s denial was arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law under the APA.
- USCIS found that Aravamuthan met only two of the ten possible regulatory criteria for "extraordinary ability" and failed the required final merits determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the denial of Aravamuthan's EB-1 petition arbitrary, capricious, or not in accordance with law? | USCIS ignored or misapplied evidence, failed to credit accomplishments, and was inconsistent with prior O-1 visa approval and prior EB-1 analyses. | USCIS considered all relevant evidence, provided rational reasoning for denial, and is not bound by prior O-1 approval or preliminary decisions. | Denial was not arbitrary, capricious, or unlawful; USCIS acted reasonably. |
| Did Aravamuthan meet the regulatory criteria for "extraordinary ability" under 8 C.F.R. § 204.5(h)(3)? | Met at least 7 of 10 criteria, supported by evidence and expert letters. | Met only 2 criteria; evidence insufficient, not widely recognized or significant as required by law. | Plaintiff failed to meet burden on disputed criteria; USCIS’s findings upheld. |
| Was the USCIS’s final merits determination reasonable? | Presented preponderance of evidence for "extraordinary ability"; agency ignored totality of evidence. | USCIS gave full review; final merits standard is rigorous, rejection reasonable under deferential APA standard. | USCIS's final merits determination reasonable, not subject to reversal. |
| Should prior O-1 approval or earlier regulatory findings bind the EB-1 adjudication? | Prior approvals show eligibility, inconsistent agency findings are arbitrary. | Each petition independent; agency can revise findings; only final action reviewable. | Agency not bound by prior decisions; no error in revised findings. |
Key Cases Cited
- Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (standard for arbitrary and capricious agency action)
- Nat’l Hand Tool Corp. v. Pasquarell, 889 F.2d 1472 (agency not bound by prior temporary visa findings for permanent petitions)
- Bennett v. Spear, 520 U.S. 154 (judicial review limited to final agency action only)