The Office of the Chief Administrative Hearing Officer (OCAHO) published a precedent decision in United States v. Zuniga Torentino, 15 OCAHO no. 1397 (2021). The case involved the immigration-related document fraud provisions of 8 U.S.C. § 1324c.

The Administrative Law Judge (ALJ) issued a default judgment against the respondent. This was due to her failure to file an answer to the complaint. She also failed to respond to a later Order to Show Cause. The ALJ decided her lack of participation waived her right to contest the allegations.

Applying Ninth Circuit law, the ALJ found that a default judgment was warranted. The judge then entered a default judgment on liability against the respondent.

The complainant had only requested the minimum civil money penalty. Therefore, the ALJ imposed that penalty on the respondent. Finally, the ALJ ordered the respondent to cease and desist from violating 8 U.S.C. § 1324c.