2002 WL 32100130 (9th Cir.)

 

For opinion see 345 F.3d 683

 

United States Court of Appeals, Ninth Circuit.

 

SPENCER ENTERPRISES, INC., Li-Hui Chang, Petitioners-Appellants,

v.

UNITED STATES OF AMERICA, Immigration and Naturalization Service, Respondents-

Appellees.

 

No. 01-16391.

March 8, 2002.

Appeal from Judgment of the United States District Court, Eastern District of California the Honorable Oliver W. Wanger Case No. CV-99-06117-OWW

 

Brief of Petitioners and Appellants Spencer Enterprises, Inc. and Li-Hui Chang

H. Ronald Klasko, Dechert, 1717 Arch Street, 4000 Bell Atlantic Tower, Philadelphia, PA 19103, (215) 994-4000.

Russell K. Ryan, Holland & Hart, LLP, 60 East South Temple, Suite 2000, Salt Lake City, UT 84111, (801) 364-9124.

 

*i TABLE OF CONTENTS

 

I. INTRODUCTION ... 1

 

II. STATEMENT OF ISSUES PRESENTED ... 2

 

III. SUMMARY OF ARGUMENT ... 4

 

IV. STATEMENT OF JURISDICTION ... 7

 

V. STATEMENT OF THE CASE ... 7

 

VI. STANDARD OF REVIEW ... 8

 

VII. STATEMENT OF FACTS ... 9

 

A. STATUTORY BASIS FOR INVESTOR IMMIGRANT PETITIONS ... 9

 

B. PROCEDURE FOR OBTAINING CONDITIONAL PERMANENT RESIDENT STATUS ... 10

 

C. INS REGULATIONS ... 11

 

D. SPENCER'S BUSINESS PLAN ... 12

 

E. INS' APPROVAL OF SPENCER BUSINESS PLAN AND SUBSEQUENT CHANGE OF POSITION ... 15

 

F. APPELLANT CHANG'S INVESTMENT USING THE SPENCER BUSINESS PLAN ... 15

 

G. EXPERT OPINIONS ATTESTING TO THE CREDIBILITY OF THE BUSINESS PLAN ... 19

 

H. DENIAL OF CHANG'S INVESTOR PETITION ... 20

 

*ii VIII. ARGUMENT ... 22

 

A. THE DENIAL OF CHANG'S INVESTOR PETITION BASED UPON A NEWLY-IMPOSED REQUIREMENT THAT THE EMPLOYMENT CREATED MUST BE PERMANENT AND CONTINUOUS CONSTITUTES AN ERROR OF LAW AND IS INCONSISTENT WITH PRIOR ADMINISTRATIVE INTERPRETATIONS ... 22

 

1. The Statute Requires "Full-Time" Employment -- not "Permanent and Continuous" Employment -- and the INS' Interpretation of the Statutory Language is Reviewed by this Court De Novo ... 22

 

2. INS Regulations Also Require Only "Full-Time" Employment ... 25

 

3. Administratively - Imposed Requirements Beyond "Full-Time" Employment are Not Supportable in Law or in Policy ... 27

 

4. An Inconsistent Agency Interpretation is Subject to Considerably Less Deference and Requires a Reasoned Explanation For the Inconsistency ... 29

 

5. Even Though Not Legally Required, FMA's Business Plan Will Produce Continuous and Permanent Employment for Ten Full-Time Employees Within the Requisite Two-Year Period ... 32

 

B. INS' DENIAL OF CHANG'S PETITION BASED UPON FAILURE TO INVEST THE REQUISITE AMOUNT OF CAPITAL IS CONTRARY TO ALL OF THE EVIDENCE ... 34

 

1. Fresno is a Targeted Employment Area, which Requires a Reduced Investment Amount of $500,000 ... 34

 

2. Chang's Investment Capital Was Placed at Risk ... 38

 

3. Chang Invested $500,000 in the New Commercial Enterprise ... 41

 

*iii C. INS' DENIAL OF CHANG'S PETITION BASED UPON FAILURE TO PROVE THE LAWFUL SOURCE OF HER INVESTMENT FUNDS UTILIZED INCORRECT LEGAL STANDARDS, WAS ARBITRARY AND CAPRICIOUS AND WAS NOT SUPPORTED BY SUBSTANTIAL EVIDENCE ... 42

 

1. Chang Complied With All Regulatory Requirements Relating to Proof of the Lawful Source of Her Investment Funds ... 42

 

2. Chang Traced Every Dollar Invested ... 45

 

D. THE CREDIBILITY OF CHANG AND HER BUSINESS PLAN IS SUPPORTED BY ALL OF THE UNCONTROVERTED EVIDENCE IN THE RECORD, AND THE AAO HOLDING TO THE CONTRARY IS NOT ENTITLED TO DEFERENCE AND NOT SUPPORTED BY SUBSTANTIAL EVIDENCE ... 49

 

1. The AAO's Holding That Chang's Investor Petition Should be Denied Because of Lack of Credibility is Arbitrary and Capricious ... 49

 

2. INS' Decision Questioning Chang's Credibility, Which Is Based Upon A Paper Record And Upon Alleged Discrepancies That Do Not Go To The Heart Of The Case, Should Not Be Accorded Deference And Should Be Overturned ... 52

 

3. This Court Should Not Give Deference to INS Opinions Outside of the Agency's Expertise; viz., the Credibility of a Real Estate Business Plan ... 57

 

4. The Credibility of FMA's Business Plan is Supported by Substantial Uncontroverted Evidence ... 60

 

E. INS DECISIONS ISSUED SUBSEQUENT TO CHANG'S INVESTMENT CANNOT BE APPLIED TO DENY CHANG'S PETITION ... 62

 

IX. CONCLUSION ... 67

 

*iv TABLE OF AUTHORITIES

 

FEDERAL CASES

 

Abovian v. INS, 219 F.3d 972 (9th Cir. 2000), amended, 228 F.3d 1127 (9th Cir. 2000) ... 53

 

Aguilera-Cota v. INS, 914 F.2d 1375 (9th Cir. 1990) ... 53, 54

 

Atchison, Topeka and Santa Fe Railway Co. v. Wichita Board of Trade, 412 U.S. 800 (1973) ... 29

 

Ayala-Chavez v. INS, 945 F.2d 288 (9th Cir. 1991) ... 59

 

Bahat v. Sureck, 637 F.2d 1315 (9th Cir. 1981) ... 65, 66

 

Bresgal v. Brock, 843 F.2d 1163 (9th Cir. 1987) ... 24

 

California Cosmetology Coalition v. Riley, 110 F.3d 1454 (9th Cir. 1997) ... 23

 

Ceballos-Castillo vs. INS, 904 F.2d 519 (9th Cir. 1990) ... 53

 

Central Ariz. Water Conservation District v. EPA, 990 F.2d 1531 (9th Cir. 1993) ... 8, 58

 

Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984) ... 23

 

Chowdhury v. INS, 249 F.3d 970 (9th Cir. 2001) ... 8, 23

 

*v ConAgra, Inc. v. NLRB, 117 F.3d 1435 (D.C. Cir. 1997) ... 30

 

Damaize-Job v. INS, 787 F.2d 1332 (9th Cir. 1986) ... 54, 56

 

Davila-Bardales v. INS, 27 F.3d 1 (1st Cir. 1994) ... 31

 

Great W. Bank v. Office of Thrift Supervision, 916 F.2d 1421 (9th Cir. 1990) ... 52

 

Hernandez-Montiel v. INS, 225 F.3d 1084 (9th Cir. 2000) ... 9

 

INS v. Cardoza Fonseca, 480 U.S. 421 (1987) ... 8, 23, 29

 

INS v. Yang, 519 U.S. 26 (1997) ... 9, 30

 

Israel v. INS, 785 F.2d 738 (9th Cir. 1986) ... 31

 

Lal v. INS, 255 F.3d 998 (9th Cir. 2001) ... 27

 

M.M. & P. Maritime Advancement Training, Education & Safety Prog. v. Department of Com., 729 F.2d 748 (Fed. Cir. 1984) ... 31

 

Martinez-Sanchez v. INS, 794 F.2d 1396 (9th Cir. 1986) ... 54

 

Masonry Masters, Inc. v. Thornburgh, 742 F. Supp. 682 (D.D.C. 1990) ... 31

 

*vi Montgomery Ward v. FTC, 691 F.2d 1322 (9th Cir. 1982) ... 27, 58

 

Omni Packaging, Inc. v. INS, 733 F. Supp. 500 (D.P.R. 1990) ... 31

 

Osorio v. INS, 99 F.3d 928 (9th Cir. 1996) ... 54

 

Pal v. INS, 204 F.3d 935 (9th Cir. 2000) ... 53

 

Parola v. Weinberger, 848 F.2d 956 (9th Cir. 1988) ... 59

 

Partridge v. Reich, 141 F.3d 920 (9th Cir. 1998) ... 8

 

Patel v. INS, 638 F.2d 1199 (9th Cir. 1980) ... 64

 

Pfaff v. U.S. Department of Housing and Urban Dev., 88 F.3d 739 (9th Cir. 1996) ... 23

 

Ruangswang v. INS, 591 F.2d 39 (9th Cir. 1978) ... 47, 63, 64, 66

 

S. Cal. Edison Co. v. FERC, 770 F.2d 779 (9th Cir. 1985) ... 24

 

Saipan Stevedore Co. v. Director, Office of Workers' Comp. Programs, 133 F.3d 717 (9th Cir. 1998) ... 58

 

Seldovia Native Association Inc. v. Lujan, 904 F.2d 1335 (9th Cir. 1990) ... 30

 

Shah v. INS, 220 F.3d 1062 (9th Cir. 2000) ... 55, 56

 

*vii Thomas Jefferson University v. Shalala, 512 U.S. 504 (1994) ... 47

 

Tovar v. U.S. Postal Service, 3 F.3d 1271 (9th Cir. 1993) ... 58, 59

 

Vilorio-Lopez v. INS, 852 F.2d 1137 (9th Cir. 1988) ... 54, 55, 56

 

Western States Petroleum Association v. EPA, 87 F.3d 280 (9th Cir. 1996) ... 30

 

INS DECISIONS

 

In re Ho, Int. Dec. No. 3362, 1998 WL 483979 (Exam. Comm. July 31, 1998) ... 38, 46

 

In re Soffici, Int. Dec. No. 3359, 1998 WL 471519 (Exam. Comm. June 30, 1998) ... 36, 46

 

FEDERAL STATUTES

 

5 U.S.C. § 706(2)(A) ... 9

 

8 U.S.C. § 1153(b)(5) ... 9, 10, 22, 34

 

8 U.S.C. § 1186b ... 10, 11, 28

 

28 U.S.C. § 1291 ... 7

 

28 U.S.C. § 1331 ... 7

 

29 U.S.C. § 2101(a)(8) ... 27

 

8 U.S.C. § 1101(a)(15)(L) ... 24

 

*viii FEDERAL REGULATIONS

 

8 C.F.R. § 204.5(i)(3)(iii) ... 25

 

8 C.F.R. § 204.6 ... Passim

 

8 C.F.R. § 214.2(l)(1)(ii) (A) ... 26

 

8 C.F.R. § 214.2(l)(3)(iii) ... 26

 

8 C.F.R. § 216.6 ... 28, 39, 45

 

8 C.F.R. § 287.1(g) ... 25

 

8 C.F.R. § 287.5(c)(3)(iv) ... 25

 

MISCELLANEOUS

 

136 Cong. Rec. 17112 (1990) ... 9, 11, 24

 

56 Fed. Reg. 60897 at 60902 (Nov. 29, 1991) ... 42

 

INS Operations Instruction 214.2(b)(11) ... 51

 

*1 I. INTRODUCTION

Appellants Spencer Enterprises, Inc. ("Spencer") and Li-Hui Chang ("Chang") seek reversal of summary judgment granted to the U.S. Immigration and Naturalization Service ("INS") and the denial of summary judgment to Appellants. Spencer is one of the largest residential home builders in the Fresno, California area. Chang is a Taiwanese national who invested $500,000 cash in FMA Enterprises, Inc. ("FMA"), a new commercial enterprise in Fresno established to build single family residences and employ U.S. workers. Chang's investment was made pursuant to a section of the Immigration and Nationality Act (8 U.S.C. § 1101, et seq.) which enables foreign nationals to obtain U.S. permanent resident status upon investing $500,000 in a new commercial enterprise which will employ ten U.S. workers in high unemployment areas such as Fresno. Chang made her investment in reliance upon INS approvals of seventeen other foreign national investors who invested the same amount of money and utilized the same business plan. INS' denial of Chang's investor petition (and its refusal to approve any other petitions subsequent to the first seventeen investors) resulted in the filing of an action seeking to overturn the denial of the investor petition as contrary to established law and arbitrary and capricious.

*2 II. STATEMENT OF ISSUES PRESENTED

A. Whether the INS erred as a matter of law in requiring that the employment created by Chang's investment must be "continuous" and "permanent" where the statute, the regulation and previous INS interpretations require only that the employment be "full-time?"

B. Whether the District Court erred in accepting the INS' finding that Chang's investment would not create "continuous and permanent employment" for ten full-time employees, when all of the uncontroverted evidence, including three expert opinions, confirm that such employment would be created?

C. Whether the INS erred as a matter of law in denying Chang's petition based upon new requirements not in existence when Chang made her investment?

D. Whether the District Court erred in accepting an INS finding that Fresno, California is not a "targeted employment area" despite the undisputed fact that Fresno's unemployment rate far exceeds 150% of the national average and despite previous INS determinations that Fresno is a targeted employment area?

*3 E. Whether the District Court erred in affirming the INS determination that Chang failed to invest the required amount when Chang invested 100% of the statutorily-required amount?

F. Whether the District Court erred in accepting the INS finding that Chang did not adequately prove the source of her investment funds when the regulation requires one of four alternative means of evidence and Chang produced all four forms of evidence?

G. Whether the District Court erred in upholding the INS finding that Chang failed to trace the source of every dollar she invested when the regulations do not require such tracing and when Chang nevertheless traced the funds from their overseas source to U.S. accounts of her business?

H. Whether the District Court erred in accepting the INS finding that Chang's business plan was not credible, when the only basis in the record to question the credibility of the business plan is INS speculation, and when three expert opinions confirm its credibility?

I. Whether the District Court erred in failing to require the INS to rationalize its denial of Chang's investor petition with the approval of seventeen other investor petitions that use the same business plan?

*4 J. Whether the INS and the District Court improperly applied new and extra-regulatory requirements to Chang's petition based on INS precedent decisions issued subsequent to Chang's investment?

III. SUMMARY OF ARGUMENT

The INS Decision denying Chang's investor petition, affirmed by the District Court, is based on application of incorrect legal standards, is arbitrary, capricious, not supported by substantial evidence and an abuse of discretion.

Both the statute and INS regulations require that the investor create "full-time employment" for ten U.S. workers. Neither the statute nor regulations require that the employment be "continuous" or "permanent," even though such requirements are contained in other statutory and regulatory provisions within the Immigration and Nationality Act. The imposition of such a requirement on Chang constitutes an error of law. In any event, Chang produced substantial evidence, including three expert witnesses opinions, that Chang's Business Plan would create employment for ten full-time employees on a continuous and permanent basis. The record contains no evidence, and no expert opinion, to controvert Chang's evidence on this point.

*5 The INS found that Fresno is not a "targeted employment area" (an area with an unemployment rate exceeding 150% of the national average). This finding is contrary to the evidence that the unemployment rate far exceeded 150% of the national average, is contrary to the INS Western Service Center's finding that Fresno is a targeted employment area, and is contrary to INS findings in seventeen other cases.

The INS also determined that 100% of Chang's investment capital was not "at risk" and that she did not invest 100% of the required $500,000. Despite only being required to be "actively in the process" of investing $500,000 and not having to complete the investment for two years, Chang invested more than the required $500,000.

Another basis for the denial of Chang's petition is failure to document the source of her funds. In fact, Chang provided evidence in full satisfaction of all four of the alternative regulatory requirements. If the INS decision requires documentation beyond the regulatory requirements, it constitutes an error of law. In any event, Chang went far beyond the regulatory requirements in tracing every dollar of the $500,100 she invested from its source overseas to the U.S. investment business. There is no suggestion that Chang's investment funds came from *6 unlawful activity. To the contrary, the record confirms that her investment funds came from employment income, real estate income, stocks and certificates of deposit owned by Chang.

Finally, the INS questions Chang's credibility and the credibility of her Business Plan. INS questions her credibility based upon a typographical error or a misdesignation of one of the eight real estate lots to be purchased. The designation of any specific lot is of no relevance to Chang's petition since the Business Plan envisions purchasing lots on an ongoing basis as lots become available. With respect to the credibility of the Business Plan, Chang produced testimony from three expert witnesses, all of whom concur that the Business Plan is credible, comprehensive and in conformity with industry standards. The INS produced no contrary evidence, but simply made an uncorroborated finding that the Business Plan is "highly unusual."

Because Chang met all statutory and regulatory requirements, and because the petition denial is based on errors of law and findings of fact for which no substantial evidence exists, the denial of the petition must be reversed.

 

*7 IV. STATEMENT OF JURISDICTION

On March 27, 2001, the United States District Court for the Eastern District of California issued a Memorandum Decision granting summary judgment to Defendant INS and denying summary judgment to Plaintiffs. [Excerpts of Record ("E.R.") 541-575] The judgment was entered on May 7, 2001. [E.R.577]

The District Court had jurisdiction over Plaintiffs' Complaint under 28 U.S.C. § 1331. This Court has jurisdiction over this appeal under 28 U.S.C. § 1291.

V. STATEMENT OF THE CASE

On August 4, 1999, Appellants and three other Plaintiffs filed in the Eastern District of California a complaint seeking a declaration, inter alia, that the INS denial of Appellant Chang's investor petition was not supported by substantial evidence, was arbitrary and capricious, constituted an abuse of discretion and was based upon errors of law. [E.R. 1-28] On May 30, 2000, Plaintiffs and INS filed cross-motions for summary judgment. [E.R. 49-94]

On March 27, 2001, the Court denied Plaintiff's motion for summary *8 judgment and granted INS' motion for summary judgment. [FN1] [E.R. 541- 575] On May 7, 2001, judgment was entered in favor of the INS. [E.R. 577] On June 29, 2001, Spencer and Chang filed their Notice of Appeal. [E.R. 578-579]

 

FN1. The Order only related to Plaintiffs Spencer and Chang. The District Court deferred ruling with regard to three other plaintiffs, who are not appellants in this action.

 

VI. STANDARD OF REVIEW

The District Court's grant of summary judgment is reviewed de novo. Partridge v. Reich, 141 F.3d 920, 923 (9th Cir. 1998). An administrative agency's interpretation of a statute is a question of law reviewed de novo. Chowdhury v. INS, 249 F.3d 970, 972 (9th Cir. 2001). Although deference should generally be granted to the administrative agency, such deference is based on an agency's expertise; and deference should not be granted when an administrative decision is not within the agency's expertise. Central Ariz. Water Conservation Dist. v. EPA, 990 F.2d 1531, 1540 (9th Cir. 1993). An administrative agency's interpretation of a relevant provision which conflicts with the agency's consistently-held earlier interpretations is entitled to considerably less deference than a consistently held agency view. INS v. Cardoza Fonseca, 480 U.S. 421, 446 n.30 (1987). Where the agency follows a settled course of adjudication, a departure from the course of *9 adjudication without a rational explanation is arbitrary and capricious. INS v. Yang, 519 U.S. 26, 32 (1997). Factual determinations by the INS are reviewed under the substantial evidence standard and are not to be accepted on appeal unless the record contains substantial evidence to support the findings. Hernandez-Montiel v. INS, 225 F.3d 1084, 1090 (9th Cir. 2000). The reviewing court shall, in accordance with the Administrative Procedure Act, set aside an administrative agency's action or decision which is arbitrary, capricious, an abuse of discretion or otherwise not in accordance with law. 5 U.S.C. § 706(2)(A) (2001).

VII. STATEMENT OF FACTS

A. STATUTORY BASIS FOR INVESTOR IMMIGRANT PETITIONS

The Immigration and Nationality Act ("Act") allocates visas for "employment creation" immigrants seeking to enter the United States to engage in a new commercial enterprise in which they invest, or are in the process of investing. 8 U.S.C. § 1153(b)(5) (2001). The legislative intent is to attract foreign capital to create employment in the United States, particularly in small U.S. businesses that employ U.S. workers. The legislative history emphasizes attracting foreign investment to high unemployment areas. See, e.g., 136 Cong. Rec. 17112 (1990).

*10 The Act makes permanent residence status available to foreign nationals entering the United States to invest in a "new commercial enterprise." 8 U.S.C. § 1153(b)(5)(A). The alien must invest or be actively in the process of investing $500,000 in a "targeted employment area" (such as Fresno), where unemployment is at least 150% of the national average, resulting in the creation of not fewer than ten jobs for U.S. workers. 8 U.S.C. § 1153(b)(5); 8 C.F.R. § 204.6(e)-(f). Pursuant to 8 U.S.C. § 1186b, an immigrant who meets these requirements and otherwise establishes eligibility for admission is admitted for permanent residence on a conditional basis as an "alien entrepreneur." 8 U.S.C. § 1186b (2001).

B. PROCEDURE FOR OBTAINING CONDITIONAL PERMANENT RESIDENT STATUS

An alien seeking conditional permanent resident status as an investor must file an I-526 petition ("investor petition") with the INS accompanied by evidence that the investment conforms with the requirements discussed above. Thereafter, the alien has two years to complete the required investment and employment. See generally, 8 U.S.C. § 1186b; 8 C.F.R. § 204.6. Upon INS approval of the petition, the alien and her dependents may apply for conditional permanent residence status good for two years.

*11 The immigrant may petition to have the conditional status removed before the second anniversary of her permanent residence. 8 U.S.C. § 1186b(c)(1). This petition must demonstrate that the alien has invested the required capital and created the requisite employment. 8 U.S.C. § 1186b(d)(1).

C. INS REGULATIONS

Recognizing that INS is not a business regulatory body and lacks expertise in regulating commercial businesses, Congress expressly encouraged INS to consult with the Departments of Commerce and State for assistance in administering investor regulations. 136 Cong. Rec. 17112 (1990).

The INS promulgated regulations (located at 8 C.F.R. § 204.6) to administer the immigrant investor program. The regulations establish that a "qualifying employee" is any employee in a position that requires at least 35 working hours per week and that the requirement to create ten full-time positions for U.S. employees within two years can be met by submitting a comprehensive business plan showing the need for at least ten qualifying employees within two years. 8 C.F.R. § 204.6(e); 8 C.F.R. § 204.6(j)(4)(B). The regulations do not require that the employment be permanent or continuous -- just full-time.

*12 The regulations require the investor to produce any one of four categories of documents -- foreign business registration records, tax returns, evidence identifying any other sources of capital or certified copies of any judgments or criminal actions -- to show that the capital invested was obtained through lawful means. 8 C.F.R. § 204.6(j)(3). The regulations do not require that all funds be traced to their original source, so long as one of the four categories of documents identifying the source of capital is produced.

D. SPENCER'S BUSINESS PLAN

Fresno, California has extremely high unemployment. [E.R. 104, 162-163, 168, 218-219, 507-510] When Plaintiff Chang filed her petition, Fresno's unemployment rate averaged 13.97%, more than three times the national unemployment rate of 4.5%. [E.R. 168, 218-219, 507-510] In addition, Fresno has a severe shortage of single family housing. [E.R. 162-163, 165-179] Although a great demand for housing exists in Fresno, and although the unemployed labor pool is available for building the houses, builders in the area have suffered from a lack of available capital. [E.R. 112-120, 177-178]

Spencer, a well-established and highly reputable residential real estate developer in the Fresno area, developed a program to address these problems by *13 identifying foreign investors willing to invest capital in the Fresno area to build homes and employ workers. [ER 158-160] Spencer went to great lengths to confirm that the INS believed its program was consistent with INS regulations, including a meeting and telephone calls with authoritative INS officials. [E.R. 96-110, 148] Upon confirmation from INS officials that its program was in compliance with the law and regulations, Spencer identified numerous foreign investors and helped them establish corporations in the Fresno area to invest the requisite amount of capital. [E.R. 96-110, 221-235] These corporations entered into sales and construction management agreements with Spencer whereby Spencer would sell lots on an ongoing basis to the investors for the construction and sale of single family homes. [E.R. 134-147, 148-151] Spencer further agreed to advise these newly-formed companies and to manage the construction employees hired by the companies. [E.R. 134-146] Spencer is highly competent to perform these services since it has constructed over 1,000 buildings since its founding in 1973 and has become widely recognized as one of California's premier builders. [E.R. 148-151, 158, 310] Spencer expended more than $1,500,000 in promoting this program in the Fresno area. With Spencer's assistance, more than 32 immigrant investors established or were establishing new businesses in the *14 Fresno area, with a total investment in excess of $14,000,000. [A.R. 96-110, 180-197, 282-286]

The details of the program are straightforward. The alien entrepreneur, an established businessperson or professional, establishes a corporation which initially purchases seven or eight developed lots at market value (normally $40,000-$60,000 per lot) in a subdivision in Fresno. [E.R. 301-315, 311, 317- 326, 363] These lots become inventory upon which the corporation will construct single family homes, usually one at a time. [Id.] The corporation pays cash for the lots, then uses the remaining portion of the initial $500,000 capital investment ($80,000 to $150,000, depending on the price of the lots) as an operating account to construct single family homes. [E.R. 134-142, 231] While Spencer serves as the sales and construction manager [E.R. 134-142], the corporation directly hires its own employees for the construction, marketing and sale of the homes. [E.R. 142, 149, 199, 206, 482] The corporation oversees the employees, makes the payroll, withholds appropriate tax deductions, maintains workers' compensation insurance and otherwise treats the workers as employees for all purposes. [E.R. 221-235] The alien entrepreneur is the president of the corporation and participates in the management of business operations. [E.R. 143-144, 199-201, 221-235, 475-494]

*15 E. INS' APPROVAL OF SPENCER BUSINESS PLAN AND SUBSEQUENT CHANGE OF POSITION

Prior to Chang's investment, seventeen investors filed investor petitions based on $500,000 investments under the Spencer business plan. [E.R. 96-110, 180-197] Each petition was approved by the INS, and the investors became conditional permanent residents. [E.R. 180-197] All seventeen businesses continue to meet or exceed the law's requirements. [E.R. 180-197, 203-208]

In 1998, the INS issued four "precedent decisions" with the goal of establishing new substantive requirements for immigrant investor petitions. [E.R. 283, 284] Although all seventeen petitions previously filed under the Spencer plan were approved, the INS has not approved one petition filed under the same plan subsequent to these decisions. [E.R. 96-110]

F. APPELLANT CHANG'S INVESTMENT USING THE SPENCER BUSINESS PLAN

Spencer identified Chang as an ideal investor given her available capital, real estate background and desire to immigrate to the United States. [E.R. 372- 374] Chang and her husband have accumulated substantial wealth both through real estate holdings and through employment. [E.R. 371, 379-432] Chang has worked for at least sixteen years in increasing level positions for the Taiwan Business Bank following graduation from the National Chung Hsing University *16 Department of Economics. [E.R. 515-519] Her husband has worked for at least seventeen years for the Chinese Petroleum Corporation and is presently the Manager of Export and Processing Department. [E.R. 515-519] Their tax returns, approved by the Taiwanese tax authorities, show six figure incomes (U.S. equivalent) yearly. [E.R. 376-377, 520-539] In addition, Chang and her husband own valuable real estate in Taiwan, including a ten story rental property and two floors of a building. [E.R. 379-432]

Relying upon INS regulations and INS approval of the seventeen investor petitions, Chang established and became President of FMA Enterprises, Inc., ("FMA") and invested $500,000 in the corporation. [E.R. 223-224, 341-342, 344- 359, 475-483, 494] The investment was placed in an irrevocable escrow account to be released upon approval of her immigrant petition. [E.R. 495] Chang wired $100 to the escrow account on May 21, 1997, followed by wire transfers of $9,983, $99,983.00, and $389,985 in August and November 1997, amounting to a total investment, less wire transfer fees, of $500,051. [E.R. 495-504] Chang utilized the same business plan and the same Spencer management agreement used by the seventeen approved investors. [E.R. 199-202, 221-236, 475-483, 494]

*17 Chang submitted a comprehensive business plan of FMA's proposed construction activities with her petition. [E.R. 221-236]. Chang agreed and is contractually obligated to purchase from Spencer subdivided lots in Fresno at market value. [E.R. 134-142, 221-236] The remaining portion of the $500,000 initial capital will pay for expenses incurred during construction of single family homes. [Id.] FMA's Business Plan is to purchase additional lots as houses are sold and to build additional homes with profits realized from the sales. [E.R. 231-236]

The initial investment amount left after the purchase of the first lots, coupled with sales revenues, is more than sufficient to construct homes. [E.R. 112-120, 221-236] In fact, utilizing this plan, FMA has more capital available to it than most residential real estate developers in the Fresno area. [E.R. 112-120, 221-236] The Business Plan includes marketing strategies, organizational structure, experience of FMA Management, staffing requirements, job descriptions, sales costs, income projections, and hiring timetable. [E.R. 221-236] FMA's strategy is to provide completed inventory lots "on a repeat, steady and ongoing basis." [E.R. 221-236]

*18 The FMA Business Plan calls for Spencer's management services for a five-year period with sales of at least six lots per year to FMA on an ongoing basis. [E.R. 134-142, 221-236] The FMA Business Plan also includes a detailed analysis of the numbers and types of employees required to build the houses and the approximate dates during the initial two-year period when each employment position would be required. [E.R. 230-231] The Business Plan realistically projects the need for at least ten to fourteen full-time employees working together both during the two-year period and thereafter. [Id.]

These workers will be direct employees of FMA compensated solely by FMA. [E.R. 142, 149, 199, 221-236] They will construct the homes with subcontractors providing only limited services. [E.R. 134-142, 142-149, 221-236] FMA obtained a business permit, purchased workers' compensation insurance and registered with the California Unemployment Department. [E.R. 493, 540]

The Business Plan does not provide for ten new employees from the beginning. [E.R. 221-236] Rather, the Business Plan envisions an initial mixture of employees and subcontractors with a phasing-out of subcontractors on later houses. [E.R. 221-236] In this way, the company can build a team of employees on an ongoing basis. [Id.]

*19 G. EXPERT OPINIONS ATTESTING TO THE CREDIBILITY OF THE BUSINESS PLAN

Chang submitted an expert opinion from Joseph J. Penbera, Ph.D. [FN2] Dr. Penbera concludes that FMA's "locational and pricing strategy is highly competitive and workable within the conditions of the [Fresno] marketplace." [E.R. 115] He observes that the Business Plan's use of a local builder to provide guidance and management oversight "is an ideal situation" and "greatly enhances the viability of the business." [E.R. 114-115] Dr. Penbera notes that "the expectation of building a house over a 5 month period and 4 houses per year to employ 10 workers is reasonable in this [the Fresno] market and consistent with current building practices." [E.R. 117] Not only does Dr. Penbera find the investment program is "extremely workable" for the Fresno market, he also finds the business plan is "credible and comprehensive" and "conforms with both industry standards" and the requirement of a comprehensive business plan in INS regulations. [E.R. 114, 118] Dr. Penbera provides a cash flow analysis explaining how Chang's investment is not only sufficient to buy necessary inventory and build the initial homes, but through profits and the return of building and construction costs, will provide Chang with substantial capital to purchase *20 additional lots and build additional homes. [E.R. 117] He also notes that less than 2% of home builders in the Fresno area have the level of capitalization available to Chang. [E.R. 117] Dr. Penbera concludes that there is a "realistic likelihood and probability" that FMA's business and the employment generated by FMA will continue on an ongoing basis. [E.R. 114 - 119]

 

FN2. Dr. Penbera's expert credentials are set forth at ER 121-129.

 

Chang also provided expert industry opinions from two other established home builders in the Fresno area. [E.R. 243-272, 273] These home builders concur that FMA's Business Plan will require the employment of ten full-time employees. [E.R. 243-244, 273] In fact, employment would be provided where it is needed most -- lesser skilled U.S. citizen workers, many of Hispanic origin, whose unemployment rate is among the highest. [E.R. 243-244, 273] The INS has not produced any evidence to contradict any of the three expert opinions.

H. DENIAL OF CHANG'S INVESTOR PETITION

On January 27, 1999, subsequent to the issuance of the above-noted precedent decision, the INS' Western Service Center denied Chang's petition, despite finding that Fresno is a targeted employment area and that Chang invested the required $500,000 of lawfully-obtained capital. [E.R. 279-300] The INS decision was certified for review to the INS Administrative Appeals Office *21 ("AAO"). [E.R. 279-300] Chang submitted substantial documentation and legal briefing to address the five specific reasons given as the sole bases for denial. [E.R. 301-338]

On April 26, 1999, the AAO denied Chang's petition. [E.R. 280] The AAO did not address the five specific grounds for denial, which Chang's counsel extensively briefed. [E.R. 279-300] Rather, the AAO set forth all new grounds for denial, which Chang had no opportunity to address. [E.R. 279-300] In fact, the AAO reversed three specific findings of the Western Service Center: (1) the "evidence of record indicates that the investor will hire ten employees" [E.R. 284]; (2) "Fresno County, California ... is a targeted employment area therefore qualifying the petitioner to make a reduced capital investment of $500,000" [E.R. 280]; and (3) Chang had made the requisite investment of $500,000. [E.R. 280] These reversals occurred with no notice and no opportunity for Chang to rebut.

The AAO, relying on the precedent decisions, also indicated an intent to deny or revoke the pending petitions filed by fourteen other investors utilizing the Spencer Business Plan. [E.R. 100-107] The AAO failed to address or mention that seventeen other investors utilizing the same business plan were previously approved. [E.R. 279-300]

*22 VIII. ARGUMENT

A. THE DENIAL OF CHANG'S INVESTOR PETITION BASED UPON A NEWLY-IMPOSED REQUIREMENT THAT THE EMPLOYMENT CREATED MUST BE PERMANENT AND CONTINUOUS CONSTITUTES AN ERROR OF LAW AND IS INCONSISTENT WITH PRIOR ADMINISTRATIVE INTERPRETATIONS

1. The Statute Requires "Full-Time" Employment -- not "Permanent and Continuous" Employment -- and the INS' Interpretation of the Statutory Language is Reviewed by this Court De Novo.

The statutory section at issue, 8 U.S.C. § 1153(b)(5)(A)(iii), requires that the investment "create full-time employment" for at least ten employees. The AAO decision was based, in part, upon a newly-imposed requirement -- not contained in the statute or the regulations -- that employment created by the investment must not only be "full-time," but also "continuous" and "permanent." [FN3] This is an incorrect legal standard as a matter of statutory interpretation and legislative history. It is also inconsistent with the duly-promulgated regulation. It is incorrect as a matter of administrative law. It is illogical as a matter of employment law.

 

FN3. Neither the INS nor the District Court questioned that the employment created by this Business Plan will be "full-time."

 

*23 The District Court held that the AAO did not abuse its discretion in creating this new and unprecedented legal standard. In doing so, it applied the wrong standard of review. [E.R. 585-560] The issue of whether the statute requires "continuous and permanent" employment is not a matter of discretion, but a question of law.

Questions of law that can be answered with "traditional tools of statutory construction" are within the special expertise of courts, not agencies, and are therefore reviewed by this Court de novo. INS v. Cardoza-Fonseca, 480 U.S. 421, 446 (1987) (quoting Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 843 n.9 (1984)); Chowdhury v. INS, 249 F.3d 970, 972 (9th Cir. 2001). This is consistent with Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 843 n.9 (1984), in which the Supreme Court stated that "[t]he judiciary is the final authority on issues of statutory construction and must reject administrative constructions which are contrary to clear congressional intent." Thus, legal issues are reviewed on a de novo basis; and no deference is given to the agency's decision. California Cosmetology Coalition v. Riley, 110 F.3d 1454, 1458, 1460 (9th Cir. 1997) (if the intent of Congress is clear, no inquiry should be made regarding whether the administrative interpretation is permissible); Pfaff v. U.S. Dep't. of Hous. and Urban Dev., 88 F.3d 739, 744 (9th Cir. 1996) (review of *24 an agency's conclusions of law de novo); Bresgal v. Brock, 843 F.2d 1163, 1168 (9th Cir. 1987) (courts are final authorities on issues of statutory interpretation); S. Cal. Edison Co. v. FERC, 770 F.2d 779, 782 (9th Cir. 1985) (court is the final authority on statutory construction and must reject administrative constructions inconsistent with the statutory mandate).

Congress did not require that any employment be permanent or continuous, only "full-time." Significantly, when Congress intended to require that employment be "continuous" in the Immigration and Nationality Act, it did so expressly. See 8 U.S.C. § 1101(a)(15)(L) (2001), which provides that an alien must have been "employed continuously" for one year to receive an L-1 visa.

The legislative history on this subject is expressly contrary to the INS interpretation. Speaking on behalf of the Senate Subcommittee on Immigration and Refugee Affairs, the proponent of the legislation, Senator Simon of Illinois stated, "[t]he only guideline is that the investment minimums must be satisfied and the venture must employ at least 10 people for 2 years." 136 Cong. Rec. 17112 (1990).

The overall Congressional purpose was to create ten full-time jobs for U.S. workers for at least two years. No Congressional purpose could be or has *25 been advanced that would require that the ten U.S. workers be the same U.S. workers at all times. Certainly, the legislative history and the statutory scheme are directly contrary to any requirement that the employment be "permanent and continuous."

2. INS Regulations Also Require Only "Full-Time" Employment.

The INS regulation requires that the new enterprise create ten "full-time positions." 8 C.F.R. § 204.6(j)(4)(i). No "continuous" or "permanent" requirement exists in the regulations. Rather, 8 C.F.R. § 204.6(e) defines "full-time employment" as employment in a position that "requires a minimum of 35 working hours per week." An investor could meet this regulatory requirement by creating ten full-time positions, even if different employees will occupy these positions at different times and even if the employees are not "continuous" or "permanent."

Other unrelated sections of the INS regulations expressly require "permanent" or "continuous" employment. [FN4] For example, *268 C.F.R. § 204.5(i)(3)(iii)(B) and (C) requires that employment be in a "permanent" research position. 8 C.F.R. § 214.2(l)(1)(ii) (A) and 8 C.F.R. § 214.2(l)(3)(iii) require employment "continuously" for intracompany transferee qualification. This distinction in the regulations is both intentional and logical since the express permanent or continuous employment requirements concern an individual employee's ability to obtain a working visa or permanent resident status in the United States. The regulation at issue here, however, relates to the ability of an investor to create full-time employment, no matter which U.S. citizen or permanent resident is employed at any given time.

 

FN4. The INS uses the term "permanent" more than 50 times -- not counting references to permanent residence -- in its regulations. In fact, in at least two sections -- 8 C.F.R. § 287.1(g) and 8 C.F.R. § 287.5(c)(3)(iv) -- it refers to "permanent full-time" employees.

 

This newly-imposed requirement of "permanent" employment is also inconsistent with the INS regulations relating to investments in a "troubled business." The only mention of duration of employment is a requirement that an investor in a troubled business present evidence of maintenance of "the number of existing employees" for at least two years. 8 C.F.R. § 204.6(j)(4)(ii). It is incongruous and in contravention of Congressional intent for the INS to require some investors to employ a certain number of employees for two years while requiring this investor to employ specific employees for a permanent period.

*27 No deference should be given to a regulatory interpretation that is inconsistent with the statute and with the clear regulatory language. See Lal v. INS, 255 F.3d 998, 1004 (9th Cir. 2001) (court need not defer to agency interpretation when the plain language of a regulation indicates a contrary meaning); Montgomery Ward v. FTC, 691 F.2d 1322, 1331 (9th Cir. 1982) (close court review required when agency's interpretation ignores commonly understood meanings of words in the rule).

3. Administratively - Imposed Requirements Beyond "Full-Time" Employment are Not Supportable in Law or in Policy.

The INS interpretation that "full-time" employment requires "permanent" and "continuous" employment conflicts with federal employment law. Pursuant to the Federal Worker Adjustment and Retraining Notification Act, an employee who works more than six months during a twelve-month period is considered "full-time." 29 U.S.C. § 2101(a)(8) (2001).

Not surprisingly, an INS official confirmed to Spencer that the type of employment created in the investment program qualified. [E.R. 95-110] If the AAO's decision is upheld, any time an employee quit or was terminated, an investor would lose eligibility for permanent resident status, irrespective of any fault of the investor, despite investing the qualifying amount and meeting all other *28 statutory requirements. Such uncertainty works directly against Congressional intent to attract foreign investment.

The District Court did not cite to any statutory, regulatory or even precedential authority as support for the AAO's new requirements. Perhaps aware of the lack of support for its holding, the District Court stated, "[e]ven assuming arguendo, that the AAO abused its discretion by adding an additional factor, Chang's build out/employment plans show that employment of 10 qualifying full-time employees is speculative." [E.R. 559]

This is yet a further new requirement, also completely inconsistent with the statutory and regulatory scheme. An investor who invests the requisite amount of capital is granted conditional residence status. That investor has two years to create the requisite employment and to file a petition to remove conditions and obtain permanent residence status. 8 U.S.C. § 1186b. Thus, the regulations first require only a plan exhibiting the need for ten employees within two years. 8 C.F.R. § 204.6(j)(4)(i)(B). Even after two years, the conditions can be removed if the investor "can be expected to create within a reasonable time ten full-time jobs for qualifying employees." 8 C.F.R. § 216.6(a)(4)(iv). Perhaps after two years, the speculative nature of an investment plan's job creation could be judged. *29 Certainly it is premature to deny a petition based on its speculative nature before employment has commenced. Such denial is especially premature given that the record contains three expert opinions that conclude that FMA's Business Plan will require at least ten full-time employees. [E.R. 112-120, 243-272, 273]

4. An Inconsistent Agency Interpretation is Subject to Considerably Less Deference and Requires a Reasoned Explanation For the Inconsistency.

The INS concedes that Chang's Business Plan is the same as at least seventeen other investors whose petitions INS approved, yet has denied Chang's petition without explaining this inconsistency. [E.R. 95-99]

The Supreme Court stated that an "agency interpretation of a relevant provision which conflicts with the agency's earlier interpretation is entitled to considerably less deference than a consistently held agency view." INS v. Cardoza-Fonseca, 480 U.S. 421, 447 (1987) (quotations omitted). The presumption is that an agency will follow settled policies, absent which the agency has a "duty to explain its departure from prior norms" in a manner which is "clearly set forth so that the reviewing court may understand the basis of the agency's action and so may judge the consistency of that action with the agency's mandate." *30Atchison, Topeka and Santa Fe Ry. Co. v. Wichita Bd. of Trade, 412 U.S. 800, 808 (1973). Specifically, where the INS follows a settled course of adjudication, a departure without a rational explanation is arbitrary and capricious. INS v. Yang, 519 U.S. 26, 32 (1997) (holding the INS did not disregard general policy but took a narrower view).

In this Circuit, the case of Western States Petroleum Ass'n v. EPA, 87 F.3d 280 (9th Cir. 1996), is on point. In that case, the EPA rendered eight decisions contrary to the decision in the case being reviewed. Id. at 283-84. This Court rejected the EPA's position that it approved eight other states' programs before it conducted a thorough review as it has now done. Id. at 284. The Court stated that, although the EPA could adjust its policies and rulings, it must clearly explain the departure for the Court to render an informed judgment. Id. This explanation must be supported by "reasoned analysis" over and above that which is required for an interpretation in the first instance, absent which the Court "need not defer to the ... anomalous interpretation." Id. at 284-85; see also Seldovia Native Ass'n. Inc. v. Lujan, 904 F.2d 1335, 1345 (9th Cir. 1990) ("[w]hen an agency reverses a prior policy or statutory interpretation, its most recent expression is accorded less deference than is ordinarily extended..." and the agency must provide a reasonable rationale supporting its departure); ConAgra, Inc. v. NLRB, 117 F.3d 1435, 1443-44 (D.C. Cir. 1997) (declining to enforce portions of an order *31 that were inconsistent with the agency's prior decision because the departure was not adequately explained); M.M. & P. Maritime Advancement Training, Educ. & Safety Prog. v. Dept. of Com., 729 F.2d 748, 755 (Fed. Cir. 1984) ("[a]n agency is obligated to follow precedent, and if it chooses to change, it must explain why").

This Circuit and other circuits have applied this less deferential standard of review to the INS. See, e.g., Israel v. INS, 785 F.2d 738, 740-41 (9th Cir. 1986) (reversing Board of Immigration Appeals decision for abusing its discretion when it failed to follow its own prior rulings in cases involving similar circumstances); Davila-Bardales v. INS, 27 F.3d 1, 5-6 (1st Cir. 1994) (there is "no earthly reason why the mere fact of nonpublication should permit an agency to take a view of the law in one case that is flatly contrary to the view it sent out in earlier (yet contemporary) cases, without explaining why it is doing so."). Furthermore, courts have reversed INS denials of employer petitions that are inconsistent with prior approvals. See, e.g., Masonry Masters, Inc. v. Thornburgh, 742 F. Supp. 682, 686-88 (D.D.C. 1990) (holding that inconsistent INS adjudications on two employer I-140 petitions for the same position is an abuse of discretion); Omni Packaging, Inc. v. INS, 733 F. Supp. 500, 502, 504 (D.P.R. 1990) (holding INS abused its discretion where it failed to apply standards consistently in approving L-1 petitions, stating that the INS must explain the departure from previous *32 decisions during the second adjudication and not in a "post hoc rationalization by counsel" or by the agency).

In the present case, INS provides no explanation for the inconsistent rulings on the same employment plans.

5. Even Though Not Legally Required, FMA's Business Plan Will Produce Continuous and Permanent Employment for Ten Full-Time Employees Within the Requisite Two-Year Period.

If this Court holds that the proper legal standard is "continuous and permanent employment," the record reveals that FMA's Business Plan qualifies. The Business Plan envisions a work force of a minimum of ten to fourteen employees who work together. [E.R. 231-232]. These will be full-time employees, working a minimum of 35 hours per week. [E.R. 231, 310] The Business Plan does not provide for ten new employees from the beginning. Rather, the Business Plan calls for a mixture of employees and subcontractors working on the first houses, with subcontractors phased-out and replaced by employees on later houses. [E.R. 230-231]

In two years, the company will always employ at least ten full-time employees. The District Court misinterprets the build-out/employment plan when it comments that the numbers of each category of employee will fluctuate. [E.R. *33 235, 560] In reality, construction workers do not specialize in only one function. The fact that three employees will perform one function during one month and no employees will perform that function during another month does not signify three terminations, but simply means employee transfers to perform different functions. Thus, the employment would be permanent and continuous -- functions would change, employees would not. [E.R. 235]

Three expert witnesses and industry trade sources concur. [E.R. 112-120, 243- 272, 273] Larry Bacowski, Vice President of Wathen Brothers Enterprises, citing the National Association of Home Builders, stated, "to complete those trades only and construct four or more houses/year of a random mix of house types, will require 10 - 12 competent trades people working at least 35 hours/week each year." [E.R. 243]

Also, Stanley Spano, President of Spano Enterprises, a builder for more than 30 years in the Central Valley of California, explained, "[b]ased on my extensive experience as a builder, it is my professional opinion that it will require no less than 10 full-time construction workers to build one of these houses over a period of three to five months." [E.R. 273] Dr. Penbera found similarly:

*34 [T]he expectation of building a house over a 5 month period and 4 houses per year to employ 10 workers is reasonable in this market and consistent with current building practices ... I conclude that the Business Plan provides a realistic likelihood and probability that full-time employment for 10 employees on an on-going basis will be created by this business venture.

[E.R. 117, 119]

Whether this level of employment will actually happen should only be examined at the end of the statutory two-year period. In the meantime, the record contains no evidence -- and certainly not substantial evidence -- to rebut these expert opinions.

B. INS' DENIAL OF CHANG'S PETITION BASED UPON FAILURE TO INVEST THE REQUISITE AMOUNT OF CAPITAL IS CONTRARY TO ALL OF THE EVIDENCE.

1. Fresno is a Targeted Employment Area, which Requires a Reduced Investment Amount of $500,000.

To qualify, an investor must invest, or be actively in the process of investing, $1,000,000. 8 U.S.C. § 1153(b)(5)(C)(i). This amount is reduced to $500,000 for a "targeted employment area," which is defined as "an area which has experienced unemployment of at least 150 percent of the national average rate." 8 U.S.C. § 1153(b)(5)(C)(ii); 8 C.F.R. § 204.6(e); 8 C.F.R. § 204.6(f)(2). To meet this requirement, an investor must submit:

*35 (A) Evidence that the metropolitan statistical area ... or the county ... in which the new commercial enterprise is principally doing business has experienced an average unemployment rate of 150 percent of the national average rate; or

(B) A letter from an authorized body of the government of the state in which the new commercial enterprise is located which certifies that the geographic or political subdivision ... in which the enterprise is principally doing business has been designated a high unemployment area.

8 C.F.R. § 204.6(j)(6)(ii).

Fresno is a targeted employment area because its unemployment rate during all relevant times has substantially exceeded 150% of the national average. [E.R. 507-510] In fact, between 1996 and 1998, the INS approved seventeen other investor petitions in Fresno based upon $500,000 investments. [E.R. 180-197, 304-307]

In the present case, the INS' Western Service Center stated, "[t]he company has been established in Fresno County, California which is a targeted employment area, thereby qualifying the petitioner to make a reduced capital investment of $500,000." [E.R. 280] Based upon this express finding, the Appellant did not provide further evidence of Fresno's status as a targeted employment area to either the Western Service Center or the AAO. In fact, the AAO's decision marked the first time the issue of Fresno's status as a targeted *36 employment area was raised. [E.R. 295] Thus, Plaintiffs were not given any opportunity to rebut or provide further evidence.

Nevertheless, the District Court upheld the AAO determination. [E.R. 563-565] This decision should be reversed because the evidence, including 1998 unemployment rates for Fresno, meets the requirement of 8 C.F.R. § 204.6 (j)(6)(ii)(A). See, e.g., Expert Opinion of Joseph J. Penbera, Ph.D., citing California Trade and Commerce Department report of 13.9% unemployment rate for Fresno for the fourth quarter of 1998; Fresno/Clovis Annual Housing Report "1999" (13.97% unemployment rate for Fresno in 1998 based upon California Economic Development Department data). [E.R. 112-120, 165-175] In addition, Plaintiff submitted official 1995 California state data confirming that Fresno is a targeted employment area based upon a 14.3% unemployment rate, far in excess of 8.4%, which was 150% of the national average. [E.R. 507-510]

The lower court cited In re Soffici, Int. Dec. No. 3359, 1998 WL 471519 (Exam. Comm. June 30, 1998), for the proposition that this official State of California data is not acceptable because the 1995 data was not from the same year as the petition. However, in In re Soffici, the INS independently obtained unemployment information for the relevant year. In that case, even though the data *37 was outdated, the INS "nevertheless independently obtained current employment information from the Florida Department of Labor and Employment Security." The INS did not follow its own practice in this case. Furthermore, the INS possessed a formal designation from the State of California for 1998 confirming that Fresno is a targeted employment area pursuant to 8 C.F.R. § 204.6(i) and 8 C.F.R. § 204.6(j)(6)(ii). See Exhibit C to the Request for Judicial Notice filed herewith.

Even if the INS did not possess this information, and even if the INS failed to follow its practice of independently obtaining this information, and even if Plaintiff's evidence did not meet the regulatory requirements, the District Court -- and this Court -- should take judicial notice both of Fresno's targeted employment area designation by the State of California and that the 1998 national unemployment rate was 4.5%. See Statistical Abstract of the United States published by the U.S. Department of Commerce, attached as Exhibit B to the Request for Judicial Notice.

To fail to take judicial notice of this fact would be to base a decision on Fresno County not being a targeted employment area, which is plainly erroneous. Such a finding should not stand. This is especially true in a situation *38 where Chang was previously advised by the administrative agency that her evidence was sufficient and then did not have an opportunity to rebut a negative finding on the same point.

2. Chang's Investment Capital Was Placed at Risk.

The District Court relied on In re Ho, Int. Dec. No. 3362, 1998 WL 483979 (Exam. Comm. July 31, 1998), in determining that Chang did not place her capital at risk. [E.R. 567] In Ho, the BIA determined that capital was not at risk because the alien had not undertaken business preparations. In Ho, the petitioner had not purchased any inventory nor office equipment, had not identified or entered into negotiations with potential suppliers, buyers or local utilities, had not explained how the business would spend the $500,000 investment, and had only deposited money into a corporate bank account.

In contrast, Chang identified and contracted with a management company, identified and contracted for the purchase of specific lots, developed an exceedingly comprehensive business plan, created Labor and Employment Directives, obtained workers compensation insurance for her employees, and registered with the California Employment Department as a corporate employer. [E.R. 199-201, 221-236, 540] She did everything imaginable to be ready to *39 commence business immediately upon the approval of her petition; however, until such approval, she has no authorization to conduct business in the United States.

The lower court apparently found dispositive that the Appellant had designated seven lots for purchase with a total sales price of $363,000. [E.R. 567-568] The lower court concluded Chang had only placed $363,000 at risk -- and not $500,000. This finding is incorrect for a number of reasons.

First, the lower court disregarded the regulation that the investor must prove only that she "is actively in the process of investing" the required amount. 8 C.F.R. § 204.6 (g)(1); 8 C.F.R. § 204.6(j). Even if Chang hadn't placed $500,000 at risk, she certainly meets and exceeds the lesser regulatory standard of being actively in the process of investing the required amount. [E.R. 308] Under the statutory scheme, Chang has two years to put the entire amount of required capital at risk to have the conditions on permanent residence removed. Even after two years, she would only have to prove substantial compliance. 8 C.F.R. § 216.6(a)(4)(iii).

Second, the distinction of whether seven or eight lots were identified for purchase initially is not dispositive. There is substantial evidence that Chang's business is an ongoing business and that she intends to purchase lots on a *40 continuing and ongoing basis indefinitely. [E.R. 134-142, 221-236] Chang has entered into a five year Sales and Construction Management Agreement with Spencer which states the "expressed policy of FMA Enterprises, Inc. to reinvest into inventory lots as initial inventory lots are sold and to construct thereon residential houses which are either already sold or built for sale." [E.R. 134-142] Spencer is obligated to "locate, offer and hold available to FMA Enterprises, Inc. additional inventory lots to replace those sold." [Id.] Spencer will provide no fewer than six lots per year to FMA. [Id.] FMA's Business Plan also states that Spencer will make lots available on an ongoing basis (Section 1.0), and FMA will reinvest profits by purchasing additional lots as houses are sold and built (Section 2.0, 5.0, 6.2, 7.0). FMA's strategy is to provide completed inventory lots "on a repeat, steady and ongoing basis" (Section 5.3). [E.R. 227-236]

That the Business Plan keeps some of the investment available for construction costs is consistent with the capital-at-risk requirement. It would defy common and business sense to do otherwise. In fact, the INS originally stated that Chang had not set aside sufficient capital after the purchase of the lots to finance the construction of homes, pay the salaries of employees, and pay other miscellaneous expenses. [E.R. 282] As Dr. Penbera described, "the risk assumed *41 by the Petitioner is ever-present and is inherent in the large capital investment that has been made." [E.R. 115]

3. Chang Invested $500,000 in the New Commercial Enterprise.

The AAO determined Chang did not invest $500,000, but rather only $499,951, after deducting wire transfer fees. [E.R. 295] Even if wire transfer fees should be deducted, the evidence contradicts the AAO's finding. Chang originally wired $100 to her escrow account in Fresno on May 21, 1997. [E.R. 495] The president of the title company maintaining the escrow account verified receipt from FMA of this $100 (which is significant since the AAO found no evidence to "verify" the source of this $100 deposit) and all other deposits. [E.R. 495] Plaintiff then wire transferred $9,983 on August 21, 1997, $99,983 on November 25, 1997, and $389,985 on November 28, 1997; for a total investment of $500,051, even after deducting $49 in wire transfer fees. [E.R. 495, 496- 504] The president of the title company verified receipt of all of these amounts. [E.R. 495] There is no evidence to support the INS' finding of an investment of less than $500,000.

*42 C. INS' DENIAL OF CHANG'S PETITION BASED UPON FAILURE TO PROVE THE LAWFUL SOURCE OF HER INVESTMENT FUNDS UTILIZED INCORRECT LEGAL STANDARDS, WAS ARBITRARY AND CAPRICIOUS AND WAS NOT SUPPORTED BY SUBSTANTIAL EVIDENCE.

1. Chang Complied With All Regulatory Requirements Relating to Proof of the Lawful Source of Her Investment Funds

Under the rubric of "source of funds," and without citing to any regulatory section, the District Court affirmed the AAO's determination that Chang did not meet the "hypertechnical requirements" to trace the path of every dollar invested. [E.R. 562]. Neither the District Court nor the AAO could cite to any regulatory section containing such a requirement because none exists. Rather, the regulations only provide that "[a]ssets acquired, directly or indirectly, by unlawful means (such as criminal activities) shall not be considered capital ..." 8 C.F.R. § 204.6(e).

This requirement carries out Congress' instruction that "processing of an individual visa not continue under this section if it becomes known to the Government that the money invested was obtained by the alien through other than legal means (such as money received through the sale of illegal drugs)." 56 Fed. Reg. 60897 at 60902 (Nov. 29, 1991).

*43 To document the source of the capital was not criminal activity, an investor must include any one of the following categories of documents: (1) foreign business registration records; or (2) tax returns filed within 5 years; or (3) evidence identifying any other source of capital; or (4) certified copies of any judgments or evidence of pending civil or criminal actions. 8 C.F.R. § 204.6(j)(3).

Even though only one category of documents is required, Chang produced documents in all four categories: foreign business records; and tax records; and evidence of other sources of capital; and a police certificate confirming no record of criminal conduct. [E.R. 367-431, 513-514, 520-539]

Nevertheless, the District Court affirmed an AAO determination that Chang failed to meet the regulatory requirement because she did not "designate the nature of her employment for three of her four jobs, and did not submit tax information for five years as the regulations require." [E.R. 562] As noted, tax returns are one of four alternative types of documentation; and the tax returns must have been filed "within five years" -- rather than all tax returns during the last five years. 8 C.F.R. § 204.6(j)(3)(ii).

It defies logic to hold that Chang did not prove the lawful nature of her assets. There is certainly no evidence to determine otherwise. There is *44 substantial evidence of the lawful source of Chang's funds, including evidence of long-term employment in significant positions with significant salaries, substantial real estate holdings, securities investments, and bank accounts. See pp. 15-16, supra.

In addition to the assets previously described, Chang and her family own stock of various companies, including Taiwan Business Bank. [E.R. 414, 416-427] Chang also held certificates of deposits at the Royal Bank of Canada totaling in excess of $200,000. [E.R. 367-342] In addition, Chang submitted her available tax returns - those for the 1994 to 1996 tax years [E.R. 520-539] These tax returns showed income (U.S. equivalence) in excess of $100,000 each year. [FN5] [E.R. Id.] The tax returns expressly reflect approval by the Taiwanese tax authorities. [Ibid.] Finally, the family produced a police certificate confirming no criminal conduct. There is absolutely no implication of criminal activity involving this investor, nor is any alleged.

 

FN5. The AAO incorrectly found that the U.S. dollar equivalent of Chang's family income for 1994 through 1996 ranged between $56,000 and $63,000. [E.R. 293] Using the proper exchange rate for those 3 years, gross income of the family ranged between $103,000 and $114,000. See Reporter's Transcript of Proceedings (September 8, 2000) at 44-45. In fact, even the after-tax income of this family exceeded $100,000. [E.R. 520-539] The exchange rate is also the subject of the Request for Judicial Notice.

 

*45 It is logical that the regulations do not require more documentation because the I-526 petition is merely the first of three steps in the immigration process. The approval of the petition provides no benefit, but merely allows filing of an application for conditional permanent residence. This second step requires an FBI and CIA security clearance. If any implication of criminal activity arises through the security clearance procedures, the petitioner is denied conditional permanent resident status. Two years later, the investor must file a petition to remove the conditional basis of the permanent resident status. As part of this process, if "it becomes known to the government that the entrepreneur obtained his or her investment funds through other than legal means (such as through the sale of illegal drugs)," the investor is given a chance to overcome such derogatory information. 8 C.F.R. § 216.6(c)(2). It is curious to note that both this regulation and the legislative history cited previously put the burden on the investor to prove that the funds were not obtained through unlawful activity only if it "becomes known to the government" that the investment funds may have been obtained through other than legal means.

2. Chang Traced Every Dollar Invested

Despite the regulatory specification of the documents that show, at the petition stage, that investment capital was not obtained through unlawful means, *46 the AAO and District Court imposed an extra-regulatory requirement on Chang to trace every dollar invested through every bank account. [E.R. 560-563] There are two problems with this requirement: (1) it does not exist in the regulations; and (2) a thorough analysis of the record confirms that Chang actually did trace every dollar invested.

As previously explained, no such regulatory requirement exists. [FN6] Certainly, the cited legislative history gives no indication of a Congressional intent to require documentation of every debit and every credit, which bears no relationship to proving that the funds were not acquired through criminal activity.

 

FN6. The District Court Judge himself appeared to be puzzled by the source of this requirement:

 

Obviously, here the AAO questions the source and questions the legitimacy of the funds, but does not explain the basis on which that is done. There is no criminal history for the applicant and there is no evidence in the record that the INS provided that the applicant, Ms. Chang, has been engaged in any kind of suspected ... unlawful activity that would be producing proceeds.

 

Reporter's Transcript of Proceedings (September 8, 2000) at 51.

 

The District Court cited In re: Soffici, Int. Dec. No. 3359, 1998 WL 471519 (Exam. Comm. June 30, 1998) and In re: Ho, Int. Dec. No. 3362, 1998 WL 483979 (Exam. Comm. July 31, 1998), in support of its position. No logical *47 reading of these decisions requires the level of documentary specificity imposed by the AAO and the District Court. If these decisions do require such an impractical degree of documentary specificity, then the decisions would be unenforceable because they impose an extra-regulatory requirement. [FN7] See Thomas Jefferson Univ. v. Shalala, 512 U.S. 504, 512 (1994); Ruangswang v. INS, 591 F.2d 39 (9th Cir. 1978).

 

FN7. See section VIII, E, infra at p. 62. See also note 12, infra, reciting the District Court's assertion, and the INS' confirmation, that

 

the case should be decided based on the regulations without reference to any changes or supplementary requirements contained in the subsequently - issued precedent decisions.

 

Finally, even if this extra-regulatory requirement is applied to Chang, the evaluation of the documentary evidence Chang produced was flawed and incorrect. Chang's extensive documentary evidence meets even the "hypertechnical requirements" that the District Court seeks to impose. [E.R. 562] Chang's evidence tracing every dollar of the $500,100 transferred funds is summarized below:

AMOUNT SOURCE

1. $390,000.00 [E.R. 498] Exchange Memo dated 11/28/97 Remitter: Li-Hui Chang

Beneficiary: Li-Hui Chang/FMA Enterprises Received by

WestAmerica Bank

[E.R. 497] Taiwanese Bank Ordering Customer: Li-Hui Chang

Beneficiary: Li-Hui Chang/FMA Enterprises Received by

WestAmerica Bank

[E.R. 496] Incoming Message dated 12/9/97 Received by

WestAmerica Bank $389,985 on 11/28/97 From: Li-Hui Chang To:

Li-Hui Chang/FMA Enterprises Received by Central Title

Company

[E.R. 595] Central Title Letter Receipt of $389,985 on

11/28/97

2. $100,000.00 [E.R. 500] Bank Document dated 11/25/97 Ordering Customer:

Li-Hui Chang Received by: WestAmerica Bank Beneficiary:

Li-Hui Chang/FMA Enterprises

[E.R. 499] Federal Funds Transfer on 11/25/97 $99,983.00

transferred From: Sender Li-Hui Chang (Royal Bank of Canada)

To: West America Bank Received by: Central Title for credit

to account of FMA Enterprises

3. $10,000.00 [E.R. 503] 8/21/97 Sender: Royal Bank of Canada Beneficiary:

Central Title Company and West America Bank For Account of

Li-Hui Chang/FMA Enterprises

[E.R. 502] Incoming Message dated 8/21/97 Sender: Royal Bank

of Canada $9,983.00 Received by: WestAmerica Bank for

Central Title for Escrow Account of Li-Hui Chang/FMA

Enterprises

[E.R. 495] Central Title received from Li-Hui Chang $9,983.00

on 8/21/97

4. $100.00 [E.R. 495] Central Title received from Li-Hui Chang $100.00 on

8/1/97

 

*49 In sum, the regulations specify the documents required for an investor to document lawful sources of capital. Chang met all the requirements, and INS does not allege any unlawful source of funds. Even though Chang met the extra-regulatory requirements, such requirements should not be upheld.

D. THE CREDIBILITY OF CHANG AND HER BUSINESS PLAN IS SUPPORTED BY ALL OF THE UNCONTROVERTED EVIDENCE IN THE RECORD, AND THE AAO HOLDING TO THE CONTRARY IS NOT ENTITLED TO DEFERENCE AND NOT SUPPORTED BY SUBSTANTIAL EVIDENCE.

1. The AAO's Holding That Chang's Investor Petition Should be Denied Because of Lack of Credibility is Arbitrary and Capricious.

The INS bases its lack of credibility finding on a typographical error on one document in a 559 page record that resulted in a misdesignation of one of the lots that Spencer proposed to sell to FMA. The AAO stated that reference in the documentation to FMA's proposed purchase of "lot 22" (which may have been *50 sold to a different company) in itself "destroys the credibility of her petition." [FN8] [E.R. 285] The specific lots to be purchased by FMA will depend upon which lots are available when Chang's petition is approved. The essence of FMA's Business Plan is not the purchase of any specific lot, but the ongoing purchase of available lots for home construction. Basing a finding of lack of credibility on such a slender thread, and then denying the entire investor petition on this basis, is not only arbitrary and capricious but truly defies logic. [FN9]

 

FN8. The AAO also makes reference to a possible discrepancy in the date of the Sales and Construction Management Agreement prepared by Spencer and to prior counsel having inserted into the record two copies of a stock certificate of Chang's husband valued at approximately $3,000 (U.S. equivalent) as affecting Chang's credibility. [E.R. 283, 292] The stock certificate was a de minimis part of the extensive documentation of the source of the $500,100 investment, which included bank accounts, tax returns, employment income, real estate holdings and rental properties. The date of Spencer's Agreement is not relevant to any issue in this case.

 

FN9. For the District Court's cogent summary of the absence of logic and reality in basing a credibility finding on this issue, see Reporter's Transcript of Proceedings (September 8, 2000) at 38-40.

 

Astoundingly, the AAO decision also criticizes Chang's "refusal to undertake any concrete business activity whatsoever until her petition is approved" and uses that as a basis to question her credibility. [E.R. 299] In reality, until the petition is approved, Chang has no legal immigration status that would allow her to *51 work or conduct business in the United States. See INS Operations Instruction 214.2(b)(11) (alien entering as a visitor for business cannot "perform productive labor or actively participate in the management of the business ...."). Apparently, to pass the INS' credibility test, Chang would have to violate U.S. immigration laws.

Also, the INS expressly allows the placement of investment money in escrow with no concrete business activity until approval of the petition. See, e.g., Memorandum from Robert L. Bach, INS Executive Associate Commissioner, dated August 28, 1998, HQ 40/6.1.3 attached as Exhibit E to Request for Judicial Notice. Following the INS' own rule apparently creates a basis for the INS to question an investor's credibility. Additionally, INS' own regulation requires the submission of a "comprehensive business plan" to show that ten qualifying employees will be employed within the next two years. 8 C.F.R. § 204.6(j)(4)(i)(B).

Chang could not have done more prior to the INS approval of her petition and grant of her legal employment status in the United States. Among other things, Chang formed a corporation, entered into an Agreement to purchase lots for development, chose lots, contracted with a general contractor to assist in *52 the sales and management of the construction business, established an escrow account with the required funds to purchase the lots and begin construction activities, purchased workers' compensation insurance, registered with the Employment Development Department to employ employees and pay employment taxes, established labor and employment directives to manage the Company's employees in accordance with normal employment practices and developed a detailed business plan. [E.R. 134-142, 221-236, 475-494, 540]

2. INS' Decision Questioning Chang's Credibility, Which Is Based Upon A Paper Record And Upon Alleged Discrepancies That Do Not Go To The Heart Of The Case, Should Not Be Accorded Deference And Should Be Overturned

The INS' "credibility" determination relating to Chang based solely on documentary evidence is entitled to considerably less deference than a credibility decision that is based upon review of a witness' demeanor. Unlike virtually all credibility issues that come before this Court, in this case no witness testimony has been evaluated by a finder of fact. Rather, all evidence is based upon a paper record. In this type of appeal, "[d]istrict court review of agency action is generally accorded no particular deference, because the district court, limited to the administrative record, is in no better position to review the agency than the court of appeals." *53Great W. Bank v. Office of Thrift Supervision, 916 F.2d 1421, 1426 (9th Cir. 1990) (quoting Asarco, Inc. v. EPA, 616 F.2d 1153, 1161 (9th Cir. 1980)). This Court is in as good a position as the AAO or the District Court to review the credibility of Chang and the Business Plan. Cf. Abovian v. INS, 219 F.3d 972, 978 (9th Cir. 2000) (explaining that deference to an immigration judge who sees the witness' demeanor does not apply to BIA paper determinations), amended, 228 F.3d 1127 (9th Cir. 2000). [FN10]

 

FN10. Furthermore, in Abovian, this Court found a due process violation where the BIA raised the credibility issue for the first time and did not afford an opportunity to explain any alleged inconsistencies. Abovian, 219 F.3d at 980. Likewise, in the present case, credibility was raised for the first time, without notice, in the decision of the AAO.

 

Even in cases where credibility determinations are based upon testimony, this Court has consistently held that a lack of credibility determination cannot survive unless the reasons for finding of lack of credibility are "substantial" and "bear a legitimate nexus to the finding." Aguilera-Cota v. INS, 914 F.2d 1375, 1381 (9th Cir. 1990). To satisfy this standard, the decision must list reasons for a finding of lack of credibility that go to the "heart" of the plaintiff's case. Pal v. INS, 204 F.3d 935, 940 (9th Cir. 2000); Ceballos-Castillo vs. INS, 904 F.2d 519, 520 (9th Cir. 1990). This Court must evaluate the reasons given for an adverse *54 credibility finding to determine whether those reasons are valid grounds. Vilorio-Lopez v. INS, 852 F.2d 1137 (9th Cir. 1988). As stated in Aguilera-Cota:

We do not accept blindly an IJ's conclusion that a petitioner is not credible. Rather, we examine the record to see whether substantial evidence supports that conclusion, and determine whether the reason employed by the IJ is fatally flawed. It is not enough that the IJ has arrived at point B from point A, or that others might also; the question we must answer is: Was it reasonable to do so?

Aguilera-Cota, 914 F.2d at 1381. "[W]hen the stated reasons for an adverse credibility finding are inadequate, this court will not find that an adverse credibility finding is supported by substantial evidence." Vilorio-Lopez, 852 F.2d at 1142. There must be a "rational and supportable connection" between the reason cited and the conclusion that the petitioner is not credible. Aguilera-Cota, 914 F.2d at 1381. "[M]inor inconsistencies or misrepresentations of unimportant facts cannot constitute the basis for an adverse credibility finding." Id. at 1382; see also Martinez-Sanchez v. INS, 794 F.2d 1396, 1400 (9th Cir. 1986) (overturning the BIA's adverse credibility finding and describing few inconsistencies as minor). Thus, neither unimportant contradictions nor "trivial errors" are proper grounds for an adverse credibility finding. Osorio v. INS, 99 F.3d 928, 931-32 (9th Cir. 1996); Damaize-Job v. INS, 787 F.2d 1332, 1337-38 (9th Cir. 1986).

*55 The Ninth Circuit Court of Appeals has held on several occasions that discrepancies in dates which reveal nothing about the issue are insubstantial to a credibility determination. Shah v. INS, 220 F.3d 1062 (9th Cir. 2000); Vilorio-Lopez, 852 F.2d at 1142. In Shah, a plaintiff sought asylum from political and religious persecution. She submitted a copy of the death certificate of her husband, whom she alleged had been murdered for his beliefs. Shah, 220 F.3d at 1066. The BIA found that the plaintiff's story not credible partly because the death certificate contained two dates. Id. at 1067. Although the dates on the certificate were over seven months apart, the Court held that this was an improper basis for an adverse credibility finding. The Court noted that the discrepancy could have been a typographical or clerical error. Further, the Court stated that if discrepancies "cannot be viewed as attempts by the [plaintiff] to enhance his claims ..., [they] have no bearing on credibility." Id. at 1068, quoting Damaize-Job, 787 F.2d at 1337 (holding that minor discrepancies in dates due to typographical errors have no bearing on credibility).

Since minor inconsistencies, such as discrepancies in dates, do not merit a lack of credibility finding, one minor discrepancy regarding one of the *56 specific lots to be purchased does not affect the credibility of the FMC Business Plan. [FN11] The issue is whether the investor intends and is contractually committed to buy lots and employ construction workers. The issue is not specific lots, since if a particular lot is sold, the investor can buy another lot. Due to the delay in the approval of Chang's petition, it is inevitable that some of the lots FMA intended to buy will be sold by the time her visa is granted.

 

FN11. Both the AAO and the District Court questioned Chang's credibility because of "ever-changing" business plans. However, new plans were not submitted; the comprehensive plan was provided in response to a request from the INS, whereas prior to that time the INS had only required an executive summary of the plan. [E.R. 293]

 

Further, Chang can incur no benefit from misdesignating the exact lots she intends to purchase. Her intent to purchase Lot 22 instead of Lot 99 does not enhance her claim, and thus it should have no bearing on credibility. Accord, Damaize-Job v. INS, 787 F.2d at 1337.

As to any possible discrepancy in the date of the Sales and Construction Management Agreement, Vilorio-Lopez and Shah provide that dates are usually not considered substantial to a credibility determination. This is especially true of dates which only convey a document preparation date. The date *57 of this document, which Chang did not prepare, has no relevance to the credibility of Chang or FMA's Business Plan.

The material issues in this case are whether Chang invested the requisite capital and whether the investment will create the requisite full-time jobs. A discrepancy in the date of the Sales and Construction Management Agreement or a possible misdesignation of one of the eight lots to be purchased is not material or substantial, and does not go to the heart of the case. These would be, at most, minor inconsistencies or discrepancies relating to unimportant facts, which are not the proper basis for an adverse credibility finding.

3. This Court Should Not Give Deference to INS Opinions Outside of the Agency's Expertise; viz., the Credibility of a Real Estate Business Plan.

In reality, this case has nothing to do with the credibility of this particular Plaintiff. Since the INS has not approved any investor utilizing this business plan since it approved the first seventeen petitions, the real issue is the business plan.

The AAO questioned whether the Business Plan's projection of at least ten employees is "realistic." [E.R. 287] The AAO, based solely on it is own judgment and without introducing any expert opinion, denigrates the Business Plan *58 as "highly unusual" and therefore not credible. [E.R. 288] This baseless finding is contradicted by the opinions of three real estate experts, all of whom conclude that the Business Plan, including the employment plan, is credible.

The basis for traditional deference to an agency's interpretations is the court's "respect for the special competence of an administrative agency to interpret a statutory provision concerning its own area of expertise." Saipan Stevedore Co. v. Dir., Office of Workers' Comp. Programs, 133 F.3d 717, 723 (9th Cir. 1998). In other words, "[t]he principle of deference to the exercise of administrative authority is derived from the court's recognition that agencies possess a body of knowledge that uniquely suits them to accommodate conflicting policies concerning matters within their own areas of skill and mastery." Tovar v. U.S. Postal Serv., 3 F.3d 1271, 1276 (9th Cir. 1993). It is therefore incumbent upon the administrative agency to demonstrate the source of the agency's knowledge on a particular subject that is not clearly within its area of expertise. Montgomery Ward & Co. v. FTC, 691 F.2d 1322, 1331 (9th Cir. 1982). A reviewing court "should not defer to the agency where it simply has not exercised its expertise." Central Ariz. Water Conservation Dist. v. EPA, 990 F.2d 1531, 1540 (9th Cir. 1993).

*59 This Court has frequently applied this tenet of judicial review in cases involving the INS. See, e.g., Avala-Chavez v. INS, 945 F.2d 288, 294 (9th Cir. 1991). For example, this Court refused to give deference to a postal regulation prohibiting employment of temporary resident aliens because "whether temporary resident aliens ... would perform less satisfactorily than permanent residents is a question not closely related to the agency's essential competence." Tovar, 3 F.3d at 1276; see also Parola v. Weinberger, 848 F.2d 956, 959 (9th Cir. 1988) (General Accounting Office's decision regarding propriety of bid and bid decision process not entitled to deference because not based upon particulars of federal contract provisions and practices, but on a statutory interpretation outside GAO's expertise).

The INS has not demonstrated expertise in real estate law or real estate development practices that would entitle its analysis of the Business Plan to deference. In fact, the record is conspicuously devoid of any expert opinion or testimony contradicting the three expert opinions introduced by Plaintiff Chang. [E.R. 112-120, 243-272, 273] The record does not contain any information as to the qualifications of the adjudicator or the AAO to review a real estate development business plan, nor is there any reference to any outside entities the INS consulted in concluding that the Business Plan is not credible.

*60 4. The Credibility of FMA's Business Plan is Supported by Substantial Uncontroverted Evidence.

There is no evidence to contradict the credibility of the Business Plan's projected need for ten full-time employees. On the other hand, three expert opinions confirm the credibility of the Business Plan's intention to employ ten full-time workers.

Stanley Spano stated that FMA's Business Plan to directly employ workers to do most of the construction work (with only specialized work performed by subcontractors) "has been used successfully by myself and other builders. It can be a very workable and effective method of house construction." [E.R. 273] The opinion of Wathen Brothers Enterprises, another builder in the Fresno area, states that ten to twelve tradespeople working at least 35 hours per week would be required to implement FMA's Business Plan. [E.R. 243-272]

Dr. Penbera, whose expert credentials are unassailable, notes that the "locational and pricing strategy is highly competitive and workable within the conditions of the marketplace." [E.R. 115] He notes that the Business Plan's model of using a local home builder to provide guidance and general management oversight "is an ideal situation" and greatly enhances the viability of the business." [E.R. 114-115] Dr. Penbera opines that "the expectation of building a house over a *61 5 month period and 4 houses per year to employ 10 workers is reasonable in this market and consistent with current building practices." [E.R. 117] In addition, he analyzes the Business Plan's projected financial statements and concludes "based upon my experience and knowledge of this market, that the return and profitability analysis contained in the Business Plan represent reasonable projections." [E.R. 115] He adds: "the investment program being utilized by the Petitioner is extremely workable for this market." [E.R. 114] Dr. Penbera concludes that, "[m]y finding is that the Business Plan is credible and comprehensive and that it conforms both with industry standards for a comprehensive business plan and with standards for a comprehensive business plan as set forth in the matter of Ho." [E.R. 118]

Specifically, with respect to the Business Plan's credibility relating to ten full-time employees, Dr. Penbera concludes:

Given the availability of capital provided by the investor, the expected turnover of houses, the normal time that is required to build a house, the availability of labor, the housing marketplace in this area and other factors contained in the Business Plan and discussed in this opinion, I conclude that the Business Plan provides a realistic likelihood and probability that full-time employment for 10 employees on an on-going basis will be created by this business venture.

*62 [E.R. 119]

The AAO arbitrarily and completely disregards the three expert opinions confirming the Business Plan's credibility. Certainly, the INS cannot claim any inherent expertise in real estate to which this Court should defer.

E. INS DECISIONS ISSUED SUBSEQUENT TO CHANG'S INVESTMENT CANNOT BE APPLIED TO DENY CHANG'S PETITION

Chang's petition is not only in full compliance with the statute and regulations, but also with the aforementioned INS precedent decisions. [FN12] However, application of any new requirement in these subsequent decisions to Chang's petition would be an error of law and arbitrary and capricious.

 

FN12. Both the District Court Judge and the INS attorney confirmed that the AAO decision was based on the statute and regulations, that the precedent decisions issued after Chang's investment are not relevant and that this case should be decided based on the regulations without reference to the precedent decisions. See Reporter's Transcript of Proceedings (September 8, 2000) at 18, 27, 28, 57, 67, 68.

 

The problems presently experienced by Chang and other investors following changes in INS interpretations of its investor regulations are strikingly similar to problems experienced by investors in the 1970s, when the INS similarly decided to change its policies by issuing precedent decisions and applying them to *63 investors, like Chang, who had no notice of such changes at the time they invested.

In a trilogy of cases involving investors in the 1970s, the Ninth Circuit dealt with issues directly on point, and arguably determinative of the issues presented here.

The first case is Ruangswang v. INS, 591 F.2d 39 (9th Cir. 1978). Mrs. Ruangswang commenced investing in January 1974. She completed investing the statutorily-required amount in March 1974 and filed her investor application in June 1974. The application was denied in 1975.

The application and the investment met the literal criteria of the INS regulation promulgated in 1973. However, the INS, on January 25, 1974 (subsequent to the initial investment and prior to completion of the investment and filing of the application), issued a precedent decision which expanded upon the regulatory requirement. Mrs. Ruangswang's investment did not meet the criteria and standards set forth in that precedent decision. The BIA denied Mrs. Ruangswang's application based on failure to meet the new standards.

The Ninth Circuit held that the denial of Mrs. Ruangswang's investor petition was in error because the precedent decision should not apply to Mrs. Ruangswang. The Ninth Circuit determined that the literal terms of the regulation *64 of which Mrs. Ruangswang had notice when she commenced investing were the only criteria that should apply. Id. at 43.

The Ninth Circuit focused on the date of Mrs. Ruangswang's initial capital outlay and determined that she had no notice of the January 25, 1974 precedent decision. The Court expressly distinguished cases in which an investment was commenced after the publication of the precedent decision. In Ruangswang, INS argued, as it has here, that the precedent decision "attempted only to clarify and strengthen the previous requirements for investor status" and "did not change the congressional intent." Id. at 46 n. 12. However, the Ninth Circuit concluded that, whether the precedent decision established new standards by adjudication or merely interpreted the regulation, it was an abuse of discretion to apply the precedent decision to Mrs. Ruangswang. The Ninth Circuit explained, "[o]n balance, the ill effect on the Ruangswangs from the Board's establishment of a standard without adequate notice outweighs any possible mischief done to the statutory design by our literal reading of the regulation based upon the facts of this case." Id.

In Patel v. INS, 638 F.2d 1199 (9th Cir. 1980), an investor began investing in July 1974 and therefore had notice of the January 1974 precedent *65 decision. The investment met the literal language of the regulatory requirement in effect when the investment was commenced, but did not meet the requirements of the precedent decision. The Ninth Circuit held that new broad, generally applicable criteria should be made by rulemaking. The Court determined the INS abused its discretion by applying the precedent decision to Mr. Patel:

In addition to our conclusion that Heitland [the precedent decision] was an improper circumvention of rulemaking procedure, we also conclude that the Board abused its discretion by applying the job-creation criterion to Patel. Although Patel invested money and applied for the investor exemption well after Heitland was decided, we doubt that he could have clearly determined what he must do to qualify for the exemption. The INS had been sending aliens confusing signals.

Id. at 1205.

Finally, in Bahat v. Sureck, 637 F.2d 1315 (9th Cir. 1981), Mr. Bahat invested and filed his petition in 1976, long after the issuance of the 1974 precedent decision. Nevertheless, the Ninth Circuit held that the combination of the 1973 regulation and the 1974 precedent decision left the law unclear. Holding that INS' application of a subsequent (1976) regulating and precedent decision denied Mr. Bahat proper notice and was an improper circumvention of rulemaking procedure, the Ninth Circuit overturned the denial of Mr. Bahat's investor petition, stating, "[t]o hold otherwise could result in a cruel hoax by encouraging *66 investments of lifetime earnings for an illusory goal." Id. at 1320. The Court also quoted Judge Sneed's concurrence in Ruangswang, which it found particularly pertinent:

Adjudication by an agency to establish a rule or policy inconsistent with its recently adopted regulation suggests administrative confusion and uncertainty. The costs of this inefficiency should not always be borne by the individual being governed. An instance in which society should bear these costs is where the individual had no reason to know that the word of the regulations is not the will of the agency.

Id.

As in those three cases, Chang made her investment (in August 1997) prior to the issuance of any of the four precedent decisions (in August 1998). [E.R. 495-500, 502-503, 595] She invested knowing that the INS, applying the literal language of the regulation, had approved seventeen investors who made the same investments in exactly the same program. [E.R. 97, 180-197, 96-110] Just as Ruangswang, Patel and Bahat had no notice of an INS change in policy, likewise Chang, at the time of her investment, had no notice of the new standards. To allow the U.S. Government to publish rules providing that investors who invest money in the U.S. and meet certain criteria will be entitled to immigrant status, and then to change the rules after investors such as Chang make their investments, would indeed be a "cruel hoax." Bahat, 637 F.2d at 1320.

*67 If the INS argues that the precedent decisions are the reason for the approval of seventeen investors using the same Spencer investor program as Chang and the denial of Chang's petition, then the rulings in this trilogy of Ninth Circuit cases are directly applicable. On the other hand, if the INS argues -- as it told the District Court [FN13] -- that the precedent decisions did not result in a change in adjudicatory standards or regulatory interpretation, then its decision is arbitrary and capricious as being inconsistent with its prior interpretations of its own regulations.

 

FN13. See note 12, supra.

 

IX. CONCLUSION

For all of the above-stated reasons, the District Court Order granting summary judgment to INS and against Plaintiffs Spencer and Chang is erroneous as a matter of law and is not supported by substantial evidence and should be reversed and remanded to the District Court with instructions to approve the investor petition of Mrs. Chang. In addition, Plaintiffs respectfully request an award of reasonable costs and attorneys fees.

*68 STATEMENT OF RELATED CASES

Pursuant to Fed. R. App. P. 28-2.6, there are no known cases related to the instant case pending in this Court.