Why should Noemi's I-485 application be denied if she has never been to the United States?

Noemi's I-485 application should be denied primarily because she is not physically present in the United States. The I-485 application, also known as the Application to Register Permanent Residence or Adjust Status, is specifically intended for individuals who are currently in the U.S. and wish to adjust their immigration status to that of a lawful permanent resident.

One of the key requirements for submitting the I-485 is that the applicant must be present in the United States at the time of filing. If Noemi has never set foot in the U.S., she does not meet this fundamental requirement, which directly affects her eligibility for the adjustment of status application.

While the concept of immigrant visa availability (as referenced in one of the other choices) is important, it is secondary to the requirement of being physically in the U.S. at the time of application. If someone is not in the country, they cannot utilize the I-485 process and must instead seek an immigrant visa through consular processing outside the United States.