Villegas-Valenzuela

Ana Villegas-Valenzuela and Martina Limon-Perez petition to overturn decisions of administrative law judges granting summary decisions in favor of the Immigration and Naturalization Service (“INS”) in two separate civil document fraud proceedings seeking civil money penalties under the Immigration and Nationality Act (“INA”), 8 U.S.C. § 1324c(a)(2). We must consider whether employees violate section 1324c(a) by using false immigration documents to prove to their employers that they are eligible for employment. Because we conclude that such use of false documents by employees violates the statute, we dismiss the petitions.

I. BACKGROUND

A. The Statutory Framework

In 1986, Congress enacted the Immigration Reform and Control Act of 1986 (“IRCA”), Pub.L. No. 99-603, 100 Stat. 3359 (1986) (codified in scattered sections of 8 U.S.C.), which amended the INA and, among other things, made it unlawful for an employer knowingly to hire an alien who is unáuthorized to work in the United States. Id. § 1324a. The statute creates an employment-eligibility verification system. Under this system, an employer- must execute a verification form (“1-9”), attesting under penalty of perjury, that…