IER Letters of Resolutions FY 2025

IER issued letters of resolution to U.S. employers who voluntarily entered into bi-lateral and unilateral settlement agreements with the charging parties resolving discrimination charges. Letters of resolution were also issued to conclude independent investigations where the employer has voluntarily corrected its practices, and no victims were identified.

The following are summaries of letters of resolutions issued in fiscal year 2024 (October 1, 2024 - September 30, 2025):

On October 8, 2024, IER issued a letter of resolution (“LOR”) dismissing a charge-based investigation into a biotechnology company’s possible unfair documentary practice based on citizenship status. IER’s investigation revealed that when the company learned that the recently onboarded Charging Party had an OPT extension which would require the company to fulfill certain paperwork – although she did not require sponsorship – the company requested a copy of the Charging Party’s permanent residency application to verify her representation that she had applied for residency. However, the investigation also revealed that the Charging Party had failed to present any valid documentation for the Form I-9.  Although there was insufficient evidence of a clear statutory violation, this conduct, if not addressed, could lead to potential violations of 1324b. The LOR memorializes the company’s unilateral commitments to ensure its employment eligibility verification personnel attend a free online IER webinar employer training on the Immigration and Nationality Act’s anti-discrimination provision, review IER and USCIS materials, Optional Practical Training Extension for STEM Students (STEM OPT) | USCIS, How to Avoid Discrimination in the Form I-9 and E-Verify Processes and Best Practices for Recruiting and Hiring Workers, and apply its Form I-9 and employment eligibility verification policies and procedures uniformly to all individuals, without regard to an individual's citizenship status, immigration status, and/or national origin, and in compliance with the requirements of 1324b. (Boston, MA)

On October 9, 2024, IER issued a letter of resolution (LOR) dismissing a charge against a security company for potential unfair documentary practices. The charging party alleged Respondent rejected the document he presented when completing the Form I-9, an I-551 stamp. Respondent reached a bilateral agreement with the Charging Party to resolve the issue. The company voluntarily committed to pay the Charging Party $1,422 in backpay and train its human resources staff and provide them with additional educational resources to avoid possible future violations of the Immigration and Nationality Act. (New York, NY)

On October 18, 2024, IER issued a letter of resolution dismissing a charge alleging that a racehorse training company engaged in hiring discrimination based on citizenship status in violation of 8 U.S.C. § 1324b(a)(1)(B). The charging party applied for employment with the company, but the earliest start date the company offered her was later than the start dates for most of its H-2B visa workers for the summer horseracing season. During the investigation, IER identified deficiencies in the company’s recruitment and hiring practices that could lead to violations of § 1324b, which the company unilaterally made several commitments to address to avoid future violations of § 1324b. The LOR memorializes the company’s commitment to pay the charging party back pay for days between when the company offered to begin her employment and the earlier date it began employing H-2b visa workers for the season; refrain from favoring visa workers over U.S. workers during the hiring process, including with respect to offering or determining start dates; and have its employees with hiring duties watch an employer training video or attend an IER employer webinar. (Saratoga Springs, NY)

On October 28, 2024, IER issued a letter of resolution (“LOR”) dismissing a charge against a restaurant for potential unfair documentary practices and national origin discrimination. Although there was insufficient evidence that the company had subjected the charging party to unfair documentary practices or national origin discrimination, IER’s investigation identified issues with the company’s practices that, if left unaddressed, could lead to statutory violations. The LOR memorializes the company’s voluntary commitment to train its employees and create written guidance for its employees involved in the Form I-9 process. (Shrewsbury, MA)

On December 3, 2024, IER issued a letter of resolution (LOR) dismissing a charge of discrimination filed against a building supply company regarding the company’s hiring practices and onboarding processes. The charging party, a lawful permanent resident who had alleged that the company did not accept his permanent resident card that had been extended by virtue of an I-797 notice of action, reached a bilateral agreement with the company through which the Charging Party received $12,000 in back pay.  The LOR memorialized the company’s commitment to undergo additional training related to the Form I-9 process and the anti-discrimination provision of the Immigration and Nationality Act. (Dallas, TX)

On December 4, 2024, IER issued a letter of resolution (LOR) dismissing a charge against a retail chain for a potential unfair documentary practice arising from the company’s termination of an U.S. citizen from Puerto Rico. IER’s investigation did not find reasonable cause to find a violation of the INA but identified deficiencies in the company’s employment eligibility verification practices as applied to the Charging Party.  IER believes that these deficiencies have been adequately addressed through the company’s unilateral action of paying $3,892.11 to the Charging Party under the terms of a bilateral agreement. (Lake Hiawatha, NJ)

On December 9, 2024, IER issued a letter of resolution (“LOR”) closing an investigation of a construction company regarding a possible pattern or practice of unfair immigration-related employment practices based on citizenship status. Although there was insufficient evidence that the company had subjected any non-citizen workers to a pattern or practice of unfair immigration-related employment practices during the relevant period, IER’s investigation identified issues with the company’s practices that, if left unaddressed, could lead to statutory violations. The LOR memorializes the company’s voluntarily commitment to ensure that certain of the company’s employees review IER’s resources regarding best practices for avoiding discrimination. The company also offered to provide a payment of $4,000 to an individual whom IER identified during its investigation as someone who sought employment with the company during an earlier period. (Charleston, WV)

On December 13, 2024, IER issued a letter of resolution (LOR) dismissing a charge against a swimming school for potential unfair documentary practices and retaliation.  The injured party, a U.S. citizen, was requested to present her Social Security card (SSC) to complete the employment eligibility verification process (EEV), even though she had presented an acceptable List A document.  The request for the SSC was also to ensure there was a name and number match for payroll and state reporting purposes.  After not producing her SSC, a few weeks later, the injured party was terminated for reasons unrelated to the EEV process. Although IER’s investigation found insufficient evidence that the employer’s actions violated the INA’s anti-discrimination provision, IER identified problems with the company’s EEV process that could lead to legal violations. The LOR memorialized the company’s voluntary and immediate participation with the Social Security Verification Number System (SSVNS), and committed to train its human resources staff who are involved in the EEV process by attending an IER webinar and comply with the rules and regulations surrounding that process to avoid possible future violations of the Immigration and Nationality Act.  As part of its EVV process, the company also committed to ensuring all new employees would be provided with a copy of the I-9 List of Acceptable Documents during the EEV process.  (Cheltenham, PA)

On January 8, 2025, IER issued a letter of resolution (LOR) dismissing a charge against a seafood processing plant involving an allegation of citizenship status discrimination, unfair documentary practices, and retaliation. The charging party alleged Respondent terminated his employment after not accepting his work authorization documents and retaliated against him by not paying for his return trip home. Although IER’s investigation found insufficient evidence of a legal violation with respect to the Charging Party, IER identified problems with the company’s employment eligibility verification process that could lead to possible legal violations. The company voluntarily committed to have its managers involved in hiring review an IER flyer and participate in an employer webinar to avoid possible future violations of the Immigration and Nationality Act. (Naknek, AK)

On January 8, 2025, IER issued a letter of resolution (LOR) dismissing a charge-based and independent investigation against an agency for potential unfair documentary practices and termination discrimination. The investigations began after a Charging Party alleged that he was unable to get a credential that allowed him to perform his job. Specifically, he alleged that the agency incorrectly believed that his Employment Authorization Document had not been automatically extended with the I-797C notice he also showed, and that he was therefore not employment-authorized. IER’s investigation identified concerns with the agency’s internal processes and understanding of employment eligibility verification documentation. The agency voluntarily committed to ensure that its policies are consistent with state and federal law, that it have a point of contact for questions about employment eligibility verification documentation (EEV), and that it notify staff of IER’s hotline as a resource in addition to the USCIS resources that staff already used. (North Carolina)

On January 15, 2025, IER issued a letter of resolution closing an investigation into possible hiring discrimination based on citizenship status. Although there was insufficient evidence that the company had refused to hire any protected individuals in violation of 8 U.S.C. § 1324b(a)(1)(B), IER’s investigation identified issues with the company’s hiring and recruitment practices that, if left unaddressed, could lead to statutory violations. The LOR memorializes the company’s voluntarily commitments that, when it assesses whether workers will require the company’s sponsorship for an employment-based work visa in the future, it will not (i) consider the worker’s national origin, (ii) ask for citizenship or work authorization documents beyond the acceptable documents that an employee chooses to present for the Form I-9, or (iii) or base its conclusion solely upon a worker’s status as a noncitizen authorized to work or the worker’s possession of an EAD. (New York, NY)

On January 15, 2025, IER issued a letter of resolution (LOR) dismissing an investigation into a financial planning company for potential hiring discrimination by limiting positions based on citizenship status. Although IER’s investigation found insufficient evidence of a legal violation, IER identified problems with the company’s recruitment practices and implementation of policies under a contract with a third party that could lead to legal violations. The company voluntarily committed to revising its hiring procedures, coordinating with the third party, and training its recruitment staff to avoid possible future violations of the Immigration and Nationality Act. (Hauppauge, NY)

On January 17, 2025, IER issued a letter of resolution (“LOR”) closing an independent investigation into a staffing company’s employment eligibility verification practices. Although there was insufficient evidence of a statutory violation, Respondent’s conduct, if not addressed, could lead to potential violations of 1324b. The LOR memorializes the company’s voluntary and unilateral commitments to ensure that its human resources and employment eligibility verification personnel owner attend a free online IER webinar employer training on the Immigration and Nationality Act’s anti-discrimination provision, review IER materials (How Employers Can Avoid Discrimination in the Form I-9 and E-Verify Processes, IER Information for Employers on How to Avoid Discrimination in E-Verify, and How to Avoid Unlawful Discrimination and Other Form I-9 Violations When Using Commercial or Proprietary Programs to Electronically Complete the Form I-9 or Participate in E-Verify), familiarize themselves with USCIS’ I-9 Central resources (www.uscis.gov/I-9Central) and IER’s free employer hotline, and have access to the most current version of the Form I-9 and USCIS Employment Eligibility Verification Handbook for Employers (M-274). (Georgetown, SC)

On January 29, 2025, IER issued a letter of resolution (LOR) dismissing an investigation into a janitorial company for potential unfair documentary practices. Although IER’s investigation found insufficient evidence of a legal violation, IER identified problems with the company’s employment eligibility verification process that could lead to legal violations. The company voluntarily committed to following E-Verify rules with respect to the citizenship status its employees select and to training its recruitment staff to avoid possible future violations of the Immigration and Nationality Act. (Saddle Brook, NJ)

On March 6, 2025, IER issued a letter of resolution (LOR) dismissing a charge against a grocery store for a potential unfair documentary practice. The charge alleged Respondent rejected the documentation the Injured Party presented when completing the Form I-9, an Employment Authorization Document that had been automatically extended by virtue of an I-797 notice of action and requested that the Injured Party return to work when he received a new Employment Authorization Document. The LOR memorializes the company’s voluntary steps to offer reinstatement and backpay to the Injured Party, as well as its commitment to train its human resources staff and provide them with additional educational resources to avoid possible future violations of the Immigration and Nationality Act. (East Greenbush, NY)

On March 12, 2025, IER issued a letter of resolution dismissing a charge alleging that a staffing company engaged in firing discrimination based on citizenship status in violation of 8 U.S.C. § 1324b(a)(1)(B). The charging party, a U.S. citizen, alleged that the company terminated him because of the company’s purported preference for temporary workers. During the investigation, IER identified deficiencies in the company’s recruitment and hiring practices that could lead to violations of § 1324b, which the company took unilateral action to address to avoid future violations of § 1324b prior to the issuance of the letter of resolution. The LOR memorializes the company’s actions, including its updates to the company’s policies to prohibit citizenship status discrimination and retaliation and its employees’ attendance at an on-demand employer training webinar. (Charlotte, NC)

On March 21, 2025, IER issued a letter of resolution dismissing a charge alleging that an IT staffing engaged in hiring discrimination based on citizenship status in violation of 8 U.S.C. § 1324b(a)(1)(B) by limiting positions to U.S. citizens. During the investigation, IER identified deficiencies in the company’s recruitment and hiring practices that could lead to violations of § 1324b, which the company unilaterally made several commitments to address to avoid future violations of § 1324b. The LOR memorializes the company’s commitment to provide the reason for any citizenship status restrictions and have its employees with hiring duties watch an employer training video or attend an IER employer webinar. (Edison, NJ)

On March 21, 2025, IER issued a letter of resolution dismissing a charge alleging that an IT staffing engaged in hiring discrimination based on citizenship status in violation of 8 U.S.C. § 1324b(a)(1)(B) by limiting positions to U.S. citizens. During the investigation, IER identified deficiencies in the company’s recruitment and hiring practices that could lead to violations of § 1324b, which the company unilaterally made several commitments to address to avoid future violations of § 1324b. The LOR memorializes the company’s commitment to have its employees with hiring duties watch an employer training video or attend an IER employer webinar and provide them with additional training materials. (Burlington, MA)

On March 25, 2025, IER issued a letter of resolution (LOR) dismissing a charge against a manufacturing company alleging an unfair documentary practice. Charging Party alleged that Respondent terminated him after rejecting his valid Employment Authorization Document (EAD) extension. During IER’s investigation, Respondent provided him $5,500 in backpay. IER’s LOR memorializes the company’s unilateral commitments to having the company’s human resources employees attend an IER employer webinar training and to issuing a notice to HR employees with USCIS guidance about work authorization for non-U.S. citizens. (Chattanooga, TN)

On March 31, 2025, IER issued a letter of resolution (“LOR”) dismissing a charge alleging that a bank committed an unfair documentary practice. The charging party alleged that he was hired for a job with the bank but confronted difficulties when he presented a receipt for his lost employment authorization document to complete the Form I-9 and was temporarily put on unpaid leave as a result. Form I-9 rules allow employees to present a receipt showing they applied to replace an acceptable Form I-9 document that was lost, stolen, or damaged. These receipts are valid for 90 days.  Due to IER’s investigation, the company agreed to pay the charging party $1,600 for the wages he lost while on unpaid leave. The LOR also memorializes the company’s unilateral commitments to train their I-9 team and provide them with educational materials to promote compliance with the anti-discrimination provision of the Immigration and Nationality Act. (San Francisco, CA)

On April 1, 2025, IER issued a letter of resolution (LOR) dismissing a charge against a staffing company for a potential unfair documentary practice arising from the company’s failure to hire a US worker. IER’s investigation did not find reasonable cause to find a violation of the INA but identified deficiencies in the company’s employment eligibility verification practices as applied to the Charging Party.  IER believes that these deficiencies have been adequately addressed through the company’s unilateral action of paying $2280 to the Charging Party under the terms of a bilateral agreement and engaging in I-9 training. (Bridgeport, CT)

On April 3, 2025, IER issued a letter of resolution (LOR) closing an investigation into allegations of unfair documentary practices and retaliation by a telecommunications company. IER’s investigation identified issues with the company’s practices that, if left unaddressed, could lead to violations of the INA’s anti-discrimination provision. The LOR memorializes the company’s voluntary commitment to ensure that certain of the company’s employees review IER’s resources regarding best practices for avoiding discrimination. (Philadelphia, PA)

On April 7, 2025, IER issued a letter of resolution (LOR) closing an investigation into potential citizenship status discrimination and unfair documentary practices by a transport and delivery company. IER’s investigation identified issues with the company’s practices that, if left unaddressed, could lead to violations of the INA’s anti-discrimination provision. The LOR memorializes the company’s voluntary commitment to ensure that certain of the company’s employees review IER’s resources regarding best practices for avoiding discrimination. (Indianapolis, IN)

On April 8, 2025, IER issued a letter of resolution (LOR) dismissing a charge against an automobile company alleging that the company questioned the validity of the worker’s Form I-9 documents during the employment eligibility verification process. IER’s investigation did not find reasonable cause to find a violation of the INA but identified deficiencies in the company’s employment eligibility verification practices as applied to the Charging Party.  IER believes that these deficiencies have been adequately addressed through the company’s unilateral action of requiring its head of human relations to undergo training on employment eligibility verification procedures. (Summerville, SC)

On April 8, 2025, IER issued a letter of resolution (LOR) dismissing a charge of unfair documentary practices against a staffing agency. The investigation began after a Charging Party alleged that the agency incorrectly rejected her extended Employment Authorization Document, which the Charging Party alleges that she presented with an I-797C receipt notice describing the automatic extension. IER’s investigation identified concerns with the agency’s internal processes and understanding of acceptable documents for the Form I-9. The agency voluntarily committed to attending an IER employer webinar and ensuring that staff responsible for employment eligibility verification understand and comply with the rules and regulations surrounding that process to avoid future violations of the Immigration and Nationality Act.  (Dallas, TX)