Human resource and hiring managers are becoming painfully aware of the potential dangers lurking behind the Form I-9 and E-Verify process. For the most part, these tales of woe stem from procedural failures such as missing or incorrectly completed I-9s, which can lead ICE to assess “paperwork” penalties and fines. The Department of Justice announced that a woman in Western New York was sentenced to one year of probation for submitting a false and fraudulent written statement on an employee’s I-9 form. The case have ended very differently – especially if she had exhibited a pattern or practice of falsifying I-9s or if the record had indicated other culpable conduct.