Aravamuthan v. US Citizenship & Immigration Service, 3:23-cv-01412

Plaintiff Srikanth Aravamuthan, an Indian citizen, sought an EB-1 “extraordinary ability” visa for permanent U.S. residence, asserting his prominence in business and management consulting.
Aravamuthan previously held an O-1 visa based on extraordinary ability and had earlier filed and been denied two EB-1 petitions before this case.
After a second denial and unsuccessful motion to reconsider, USCIS reopened the petition, issued a Notice of Intent to Deny (NOID), evaluated further evidence, and ultimately denied the petition again in November 2023.
Aravamuthan filed for judicial review claiming the denial was arbitrary, capricious, and contrary to law; both parties moved for summary judgment.
The case was decided under the Administrative Procedure Act, with the court reviewing whether the agency acted arbitrarily or capriciously in its evaluation of evidence related to the EB-1 visa criteria.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Arbitrary/capricious USCIS step-one analysis	USCIS incorrectly applied EB-1 criteria, disregarding evidence for multiple regulatory categories	USCIS considered the evidence and provided rational explanations for not finding several criteria met	USCIS’s decision was reasonable and not arbitrary or capricious
USCIS’s step-two (final merits) determination	Evidence shows sustained national/international acclaim; USCIS ignored weight of evidence	Evaluation was reasonable, and plaintiff failed to meet stringent "extraordinary ability" standard	USCIS’s final merits decision not arbitrary or capricious
Prior O-1 approval and inconsistent USCIS findings	EB-1 should be approved since O-1 was previously granted and past findings were inconsistent	Each petition is independent; USCIS may revise prior findings and only final action is reviewable	O-1 approval is non-determinative; focus is on latest, final agency action
Harmless errors in criteria evaluation	Errors in not crediting certain articles/evidence were prejudicial	Any error was harmless since criteria were otherwise satisfied and overall burden not met	No grounds for reversal; any minor errors harmless

Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (arbitrary-and-capricious standard for administrative review)
Bennett v. Spear, 520 U.S. 154 (definition of final agency action for judicial review)
Nat’l Hand Tool Corp. v. Pasquarell, 889 F.2d 1472 (standard for reversing agency decisions under APA)
Tex. Oil & Gas Ass’n v. EPA, 161 F.3d 923 (limits of arbitrary-and-capricious review and agency expertise)