Executive Summary: On July 8, 2015, an administrative law judge (ALJ) ordered Hartmann Studios to pay a fine of over $600,000 for more than 800 I-9 paperwork violations, the largest fine awarded by an ALJ for paperwork violations to date. In United States v. Hartmann Studios, Inc. (OCAHO Case No. 14A00008), the ALJ found the employer liable for 808 of the 818 Form I-9 paperwork violations alleged by the government. Although the judge refused to entertain Hartmann’s financial hardship defense due to its failure to provide audited financial statements or otherwise respond to the government’s discovery on its ability to pay the government’s proposed civil money penalty ($812,665.25), she made modest downward adjustments in the proposed base penalties, but increased the aggravation penalties for violations associated with unauthorized workers, resetting the fine amount at $605,250.
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