In U.S. v. Golf International, an employer contended that E-Verify participation should entitle it to a presumption that it did not violate immigration laws after being issued an initial fine of $136,697 for failing to properly complete Form I-9 Employment Eligibility Verification Documents for its employees. The Office of the Chief Administrative Hearing Officer of the U.S. Department of Justice (OCAHO) ruled that E-Verify provides no such blanket protection to employers.  In its decision, the OCAHO cited the E-Verify Memorandum of Understanding that must be signed by all participating employers, which states: “The Employer understands that participation in E-Verify does not exempt the Employer from the responsibility to complete, retain, and make available for inspection Forms I-9 that relate to its employees.” OCAHO issued a partial summary decision in favor of the U.S. Immigration and Customs Enforcement and ruled that despite its enrollment in E-Verify, the employer was liable for 129 Form I-9 violations.