Schneider

Plaintiffs-Appellants Stefan Schneider, Anwar Tandar, Komsu Mamuya, and Sara-vanan Kasthuri (“Immigrant Doctors”) are medical doctors who practice in designated medical shortage areas. The Immigrant Doctors seek adjustment to lawful permanent resident (“LPR”) status based on their employment. The Immigrant Doctors brought an action against the Secretary of Homeland Security (“Secretary”) in federal district court for declaratory and injunctive relief, challenging the validity of several regulations that implement the Nursing Relief for Disadvantaged Areas Act of 1999 (“Nursing Relief Act”), Pub.L. No. 106-95, 113 Stat. 1312 (Nov. 12, 1999) (codified at 8 U.S.C. § 1153 (b)(2)(B)(ii)). The district court denied the Immigrant Doctors’ motion for summary judgment and dismissed the action. The Immigrant Doctors filed this timely appeal. For the reasons set forth below, we affirm the district court in part and reverse in part.

I. STATUTORY FRAMEWORK

At issue in this case is the national interest waiver that provides an accelerated path to LPR status for immigrant doctors who practice in medically underserved areas. Absent a national interest waiver, an immigrant doctor generally…