It's a farm, a family owned business. Re MSM the paperwork was handled by a family employee. If she used the on line version of the SSNVS system, she was using an electronic verification system, just not THE E-Verify system. "Sure I e-verify, I vet the SSNs electronically on line." , and indeed they might have, but not with E-Verify.
THAT ALL HAVING BEEN SAID...
Per MSM the Senior Y Farm owner was on the Iowa Agriculture Board, lobbying the Feds to free up more farm worker visas. He must know the ins and outs of the system. His farm operated within the letter of the law, and his agent using the electronic version of the SSNVS gives him plausible deniability in court over this issue, and the shield of the SSNVS handbook and EEOC law gives him further legally sanctioned ground to justify his conduct.
NEVER skirt the shoals of the law, unless you know where all the rocks are first. To not cross the line, you must first know where it is at. The way the farm operated was by the letter of the law legal. To file charges, the Feds will have to show that they had actual knowledge that they were hiring illegals and/or somehow participated in the fraud, even though EEOC laws mandate that you can't ask hires questions about this. Certainly, there may well be administrative fines, just the cost of doing business.
Do you see all the marvelous wiggle room that this gives a well paid high dollar immigration law attorney in court, as part of a Criminal defense team for Y Farms and it's owners and staff. While we could fantasize about a RICO criminal conviction and Tort over all of this with triple damages, and involving other farms,; the owners could also throw the family member, who filed on the SSNVS as the registered authorized employer's agent, under the bus as she was the one ultimately responsible for the fraud. "We'll put money on your commissary books and pay for your phone calls. Of course, you'll always have a home here when you get out..."
Thanks for your kind post. Anything is possible. Only time will tell.