OCAHO on Document Abuse: USA v. Life Generations Healthcare

"Statistical and anecdotal evidence amply demonstrates that during the period when Lani Pulmano and Regina Czerwinski were in charge of I-9 completion at St. Francis Pavilion, their standard operating procedure was to require noncitizens and perceived foreign-born individuals to present List A documents, as well as to present more and different documents than necessary for the purpose of satisfying the employment eligibility verification system. Dr. Gobalet’s testimony was both powerful and persuasive as to the statistical significance of the disparities reflected in her reports, and anecdotal evidence presented by the testimony of a number of employee witnesses provides
additional corroboration that specific and excessive documents were routinely required from USC-F, LPR, and AAW employees and applicants. That is to say, Pulmano and Czerwinski regularly and purposefully applied more rigorous requirements to persons they perceived to be foreign-born than they applied to citizens of the United States whose documents did not reflect foreign birth. These latter individuals were generally permitted to present whatever documents they chose. While Generations suggests that any requests for specific or excessive documents were isolated, sporadic, or accidental, this assertion is belied by the bottom line: U.S. citizens were generally hired without having to present List A documents or excessive documents, but no noncitizen was hired without presenting both a List A document and more documents than required to satisfy the requirements of the employment eligibility verification system." - USA v. Life Generations Healthcare, Sept. 11, 2014.