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I-9 E-Verify Immigration Compliance

ICE Targeted 7-Eleven Stores for “Silent Raids”

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By: Bruce Buchanan, Sebelist Buchanan Law

As discussed in my prior blog entry ( that Immigration and Custom’s Enforcement (ICE) would be targeting a national food service chain, ICE delivered Notice of Inspections (NOIs) (sometimes referred to as “silent raids”) at 98 7-Eleven stores nationwide on January 10, 2018 demanding to see the I-9 forms of all employees. Furthermore, ICE detained 21 employees.

The 7-Eleven stores involved are in 17 states, including California, Florida, Michigan, Missouri, New Jersey, New York, Pennsylvania, and Texas. 7-Eleven, Inc. issued a statement stating each of the stores is a franchise, who is “solely responsible for their employees, including who to hire and verifying their eligibility to work in the United States.” Furthermore, it stated that the franchise agreements of franchisees “convicted” of violating immigration laws, have been terminated.

ICE referred to their recent actions as a “follow-up” of a 2013 investigation that resulted in the arrests and convictions of five franchise owners in New York and Virginia for harboring undocumented workers and wire fraud. Because of these convictions, it spawned the largest forfeiture in ICE history – forfeiture of franchise rights to 14 stores, forfeiture of five houses, valued at $1.3 million, and restitution of over $2.6 million for back wages stolen from employees. See my blog entry ( for October 6, 2014 for more details on the 2014 convictions.

Thomas Homan, acting director of ICE, issued a statement – “Today’s actions send a strong message to U.S. businesses that hire and employ an illegal workforce: ICE will enforce the law, and if you are found to be breaking the law, you will be held accountable.”

One of the unique aspects of the delivery of NOIs is the detention of 21 employees. In the Obama administration, which issued thousands of NOIs every year, ICE would not normally detain workers at the time of the NOI; rather, ICE would issue a Notice of Suspect Documents to the employer stating the named employees’ documentation did not demonstrate work authorization. Then the employer gave the employee an opportunity to provide “new” documentation. If employees were unable to provide valid documentation, the employer had to discharge the employees or face penalties. However, at no point in this process did ICE seek to detain undocumented workers.

Homan had previously stated ICE was going to detain undocumented workers during NOIs and now we know how ICE is going to accomplish this. Unless ICE can establish that the employer was aware or should have been aware of the workers’ undocumented status, the employer will not face civil penalties or criminal penalties. In ICE’s previous actions toward 7-Eleven franchises, it established knowledge of undocumented status.

After the indictments and convictions of the store owners in New York and Virginia in 2013 and 2014, 7-Eleven’s corporate office stated it would “take aggressive actions to audit the employment status of all of its franchisees’ employees.” However, 7-Elevens recent statement appears to try and wash their hands of any responsibility or liability for the franchisees’ actions.

I will keep you abreast of future developments in the case. For a review of ICE’s civil and criminal actions against employers as well as other employer immigration compliance issues, I invite you to read The I-9 and E-Verify Handbook, a book that I co-authored with Greg Siskind, and is available at

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