A husband and wife team started a bakery in San Antonio, Texas, despite having no prior experience in the business. Unfortunately, their inexperience caused them to improperly complete Form I-9s for their employees. Immigration and Customs Enforcement conducted an I-9 inspection and found thirty-two violations. ICE issued a Notice of Intent to Fine $30,574.50. ICE claimed the penalty was appropriate because the high rate of violations showed that the couple did not engaged in a good faith effort to comply with the law. The Office of the Chief Administrative Hearing Officer disagreed and held that bad faith requires a showing of culpable conduct beyond merely a high rate of violations. The OCAHO ordered the couple to pay a $14,600 reduced penalty. While the couple got some relief, a $14,600 fine is still a huge burden for a small mom and pop shop and it shows the importance of implementing a Form I-9 process and policy, no matter the size of the business.