Got Pay Stubs? Transferring H1B Without Pay Stubs

An all too common question that immigration lawproperly terminated unless the employer tells
attorneys dealing with H1B cases encounter isUSCIS that the relationship has been terminated
whether it is possible for an H1B worker to portso that USCIS may cancel the I-129 petition, and
his or her employment to a new company if thisthe employer must provided the employee
worker does not have recent pay stubs.payment to fly back home. Case law precedents
Consider the example of R.S. Singh. After Singhdictate that even in cases where the employer
graduated with distinction from a reputable Indiannotified the employee, but not USCIS of the
university, he was offered a job by a UStermination, the H1B remained valid until the end
consulting firm, YKK Infosys, promising to pay himof the LCA period, and the former employee is
$60,000 a year as a systems analyst. YKK filedable to collect back pay with interest. In one case,
his H1B petition with the US Citizenship andwhere the employer was found to have violated
Immigration Service, and the petition gotH1B/LCA regulations on numerous occasions, the
approved. Shortly thereafter, Singh obtain his visaDOL Wage and Hour division successfully pursued
and gained admission to the US.a backpay award of over $980,000.
As soon as Singh arrived, willing and able to work,Employers may claim the employee acted in bad
the employer put Singh on "bench" without pay.faith as well, but still, the employer was held
He was told that he would only be paid if he wasresponsible. Even in a case where the employee
placed on a project. The employer took somemisrepresented his credentials, given the employer
initiative to market him to potential clienta reason to terminated him, because the
companies with no success. A few months later,employer did not notify USCIS, the clock requiring
through Singh's own job-hunting efforts, he foundthe employer to cover backpay continued to run.
a project and was finally put to work... for 4Note that damages accrue from the time the
months. During those 4 months of work, Singhemployee makes him or herself available for
worked 50-60 hours a week, produced excellentwork. Even if there is no work available, the
quality work, but was paid a paltry $2000 aemployer may not use that as an excuse not to
month - well below the prevailing wage of apay the employee.
systems analyst. Of course, YKK was skimmingOther Legal Damages: In addition to the DOL
their share of several thousands of dollars fromrequiring the employer to pay fines and back pay
the client. Once again, Singh would have to lookfor its violations, an aggrieved H1B worker can,
for work while his employer paid him nothing.for example, seek a claim in federal court based
As bad as the above scenario seems, in someon RICO violations. Potentially, the employer could
cases, it has been observed that companies runbe required to pay triple the value of unpaid
an audacious scheme in which they charge awages ("treble damages") in addition to attorney
thousand dollars or more to the foreign workerfees.
just to file the H1B, and if approved, they chargeIn reality, the majority of consulting companies
several thousand more dollars to file for the visaare legitimate business operations. The above
to bring them in. Returning to our example,liabilities should be considered a warning to
months later, Singh finally found a legitimatecompanies who think they are being fair to
employer who offered to port his H1Bemployees who they are no longer able to
employment. The new employer's immigrationsupport. Because for every situation like Singh's,
attorney requested that Singh provide his paythere is a situation where an employer pays their
stubs for the past three months to show proofH1B employee well, but unfortunately has to
that he was maintaining his H1B status.terminate the employment prematurely because
Singh replied that he had none, and was worriedof a sudden downturn. Following the book, the
that he was out of status as a result.employer informs the employee that it will be
Unfortunately, many H1B workers do not realizeterminating the job and paying for the employee's
they have a lot of power with the law being onairfare to return home.
their side, and quietly endure months of hardship.But then the employee might plead with the
They fear that if they complain too much, theiremployer to "park" their H1B, and offer to pay
employer will just notify USCIS that the position isthe employer to run pay roll because that
terminated, and force the worker to return toemployee would rather not return home. In such
their home country. In reality, as an H1B worker,a case, the employer is obviously running a risk in
Singh has the opportunity to file a complaint totrusting that the employee will not later report
the Department of Labor to obtain unpaid wages,them for illegal benching. The message is that H1B
and can use this complaint in lieu of pay stubs.employees should recognize the fact that they
This gives any illegally benched employee a lot ofhave rights, and honest and dishonest H1B
leverage against his unscrupulous employer.employers alike should realize that they have to
Consider the following liabilities that YKK would bebe very careful not to violate these rights.
potentially subjected to:This article is made available by the lawyer or law
General Penalties: Failure to comply with all LCAfirm publisher for educational purposes only as well
requirements may result in fines from $1,000 toas to give you general information and a general
$35,000 per violation, and debarment from allunderstanding of the law, not to provide specific
future approvals of visas or Labor Certificationslegal advice. By using this website you understand
for at least one year.that there is no attorney client relationship
Back Pay: In cases where the employer does notbetween you and the website publisher. The
pay prevailing wage, it can be ordered to paywebsite should not be used as a substitute for
backpay to make up for the deficiency. Thecompetent legal advice from a licensed
obligation to pay the employee may not beprofessional attorney in your state.