Employers must carefully follow the rules for Form I-9, Employment Eligibility Verification to avoid significant liability in a government inspection. An employer with operations in the States of Washington and Oregon recently learned this lesson the hard way. In January 2022, an Administrative Law Judge (ALJ) imposed I-9 fines of $1,527,308.90 against that employer.
The employer was a staffing company. It employed less than 50 full-time, regular employees but hundreds of seasonal employees at various points in the year. Immigration and Customs Enforcement (ICE) received a tip that this company was not complying with the I-9 rules and commenced an inspection of the company’s Forms I-9. The inspection covered the I-9s for current and former employees within the retention period. After a two-year investigation, ICE issued a Notice of Intent to Fine that sought more than $2 million in I-9 penalties. At the later hearing, the ALJ substantially agreed with ICE and imposed a fine of more than $1.5 million. The ALJ imposed this high fine even after giving leniency by treating the employer as a small business based upon the number of full-time, regular employees.
The ALJ determined that the employer committed numerous, serious violations, including the following:
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