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USA v. Frio County Partners, Inc., Apr. 22, 2016 - "ICE charged FCP with failing to ensure proper completion of section 1 of the Employee Eligibility Verification Form I-9 and/or failing to properly complete section 2 or section 3 of the Form I-9 for eighteen employees. ICE assessed a total penalty of $15,988.50. ... Although I agree with ICE’s assessment of the statutory factors, based on a review of the totality of the evidence, the undersigned finds that the penalties proposed by ICE are disproportionate to the Form I-9 violations and mitigating factors present in this case. ... the total civil money penalty assessed for all eighteen violations is adjusted to $10,550."