The Office of the Chief Administrative Hearing Officer (OCAHO) published a precedent decision in United States v. Koy Chinese & Sushi Restaurant, 16 OCAHO no. 1416d (2023), a case arising under the employer sanctions provisions of 8 U.S.C. § 1324a. The Chief Administrative Hearing Officer (CAHO) issued a Notification of Administrative Review of the Administrative Law Judge’s (ALJ’s) final order on penalties. The CAHO informed the parties that he would be reviewing three issues related to the ALJ’s order: (1) whether the ALJ’s imposition of a particular civil penalty amount for some of the violations was appropriately supported by the record; (2) whether the ALJ’s decision to enter a default judgment as to liability and bifurcate the proceedings was appropriate in light of both parties’ lack of participation in the case; and, (3) whether it was appropriate for the ALJ to reject the parties’ settlement agreement and deny their motion to approve consent findings based on that settlement agreement.