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  • 1.  Employee with pending DACA renewal

    Posted 03-02-2026 08:51

    Good morning,

     

    Has anyone dealt with a city employee who has protection of DACA? I am looking for guidance for an employee who has DACA status, and she submitted her application for renewal, which in the past has been granted quickly and timely. This year, she submitted her renewal application, and it is still in pending status. The issue is that her employment authorization document (EAD) is set to expire soon. City administration wants to put her on unpaid leave until her renewal application has been approved because she is a good employee and they don't want her to lose her accrued benefits.

     

    I cannot find any legal authority that would prevent the city from placing her on unpaid leave versus terminating her employment. Any guidance is appreciated.

     

    Thank you.

     

    Jennifer

     

    A blue and gold letter r  AI-generated content may be incorrect.

    Jennifer N. Rowling  | Attorney

    TYE & ROWLING, PC LLO

    Counselors & Attorneys at Law

    jnr@tyelaw.com | www.tyelaw.com

    P:

    308.237.3155   F: 308.236.7780  

    1419 Central Avenue

    PO Box 636
    Kearney, NE 68848-0636

     

     

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  • 2.  RE: Employee with pending DACA renewal

    Posted 03-02-2026 09:14

    Oh gosh, Jennifer, what a tough situation! I am going to cross-post this to our Immigration Law section to see if anyone has any advice for this group. I will reply all with that information in case it is helpful to others.

    Bri

     

    To accommodate my hearing loss, I rely on captioned communication. I am best reached via Email, Text, or Zoom. Thank you for your understanding!

     

    Bri Petersen, MA, PMP (she/her)
    Section Facilitator and Publications Director

    Nebraska State Bar Association

    635 S 14th St. #200 | Lincoln NE 68508
    Office Line: (402) 742-8126

    Mobile (Call or Text): 402-890-0183

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  • 3.  RE: Employee with pending DACA renewal

    Posted 03-02-2026 09:41
    Here are my thoughts-

    The Immigration Reform and Control Act of 1986 (IRCA), codified at INA § 274A(a)(2), makes it unlawful for an employer to "continue to employ" an individual the employer knows is unauthorized to work in the United States. However, the critical question is whether "continue to employ" requires full termination, or whether ceasing all work activity through unpaid leave satisfies the statute. IRCA defines "employee" as "an individual who provides services or labor for an employer for wages or other remuneration". Under this definition, an individual on unpaid leave who is neither performing services nor receiving compensation arguably falls outside the definition of "employee" for IRCA enforcement purposes
    The Department of Homeland Security has not published formal guidance addressing whether employers must fully terminate or may use unpaid leave during an EAD gap. This absence of official guidance means both approaches-unpaid leave and termination/rehire-remain available to employers, with varying levels of legal risk.  The Incalza v. Fendi Decision (9th Circuit) is insightful. Incalza v. Fendi North America, Inc., 479 F.3d 1005 (9th Cir. 2007). In that case, the U.S. Court of Appeals for the Ninth Circuit held that a gap in employment authorization did not constitute good cause for termination because a leave of absence was a viable alternative consistent with IRCA. The court reasoned that an employer should grant a leave of absence for a reasonable period of time when there is a gap in employment authorization, rather than proceeding directly to termination.
    While this decision only controls in the Ninth Circuit (which does not include Nebraska), it is persuasive authority and reflects the most developed judicial reasoning on this issue. No federal appellate court has held that termination is required during an EAD gap
    If you do face a gap in work authorization – your EAD expires but your renewal is still pending – you have limited options. You cannot work legally during this period. But you might be able to preserve your job.
    Some employers are willing to place employees on unpaid leave of absence during authorization gaps. This isn't termination – your position is held, your seniority is preserved, and you return to work when your new EAD arrives. This requires employer cooperation, but its worth asking.
    If your employer agrees to a leave of absence, get the terms in writing. Specifically request that your reinstatement will be at the same position (or comparable) with seniority corresponding to your original hire date. Make sure the leave is classified in a way that doesn't affect your benefits eligibility or tenure status.
    Your employer is not obligated to offer this. They can legally terminate you when your work authorization expires. But many employers value there employees and would rather hold a position open for a few weeks or months then lose someone and start the hiring process over. It doesn't hurt to ask, especially if you have a good relationship with your employer.
    Many employers-including universities, municipalities, and private companies-routinely place employees on unpaid leave during EAD gaps rather than terminating. Vanderbilt University, for example, has a formal policy placing employees on leave without pay when a new EAD is not in hand at expiration, with termination occurring only if the gap extends beyond six weeks. This demonstrates that the unpaid leave approach is a well-established and accepted practice. https://hr.vanderbilt.edu/employee-immigration-services/ee_with_ead_rules_regs/

    Good luck and if I can help let me know. 




    George Achola
    Attorney at Law |
    Communitas – Law & Economic Development Group

    10404 Essex Court, Suite 101, Omaha, NE 68124
    Phone: 402-503-8100 | Email:
    GAchola@communitaslaw.com

    Fortitudine Vincimus -Through endurance, we conquer.

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  • 4.  RE: Employee with pending DACA renewal

    Posted 03-02-2026 12:05

    Thanks, George. Here is a comment from Professor Ruser at UNL as well (I didn't think about reaching out to a rep to expedite – worth a shot!):

     

    This is a question that others are more likely able to answer than I am, since I don't have any direct experience advising employers, but I am looking at 8 USC 1324a(a)(2), which reads as follows: It is unlawful for a person or other entity, after hiring an alien for employment in accordance with paragraph (1), to continue to employ the alien in the United States knowing the alien is (or has become) an unauthorized alien with respect to such employment.

     

    So, again, I defer to the employment lawyers on this list, but my cursory reading of this provision is that if the person would still be considered an "employee" while on administrative leave, that could be a problem.

     

    Tangentially, I would suggest reaching out to a Congressional representative and/or doing a FOIA request to see if the process could be accelerated. We have had some success in the past with Congressional inquiries producing results.

     

     

    To accommodate my hearing loss, I rely on captioned communication. I am best reached via Email, Text, or Zoom. Thank you for your understanding!

     

    Bri Petersen, MA, PMP (she/her)
    Section Facilitator and Publications Director

    Nebraska State Bar Association

    635 S 14th St. #200 | Lincoln NE 68508
    Office Line: (402) 742-8126

    Mobile (Call or Text): 402-890-0183

    facebook-32twitter-32linkedin-32

    NSBA Logo

     






  • 5.  RE: Employee with pending DACA renewal

    Posted 03-02-2026 13:54

    Jennifer,
    Thank you for sharing Professor Ruser's analysis. He's correctly identified the operative statute-8 U.S.C. § 1324a(a)(2)-and his concern is the right one to raise. The question is exactly as he frames it: is someone on unpaid administrative leave still being "employed" for IRCA purposes?​
    The answer, in my view, is no-provided the city does it correctly. IRCA ties "employment" to the provision of services or labor for remuneration. An individual on unpaid leave who is performing no services and receiving no compensation is not being "employed" in any functional sense under IRCA, even if she remains on the city's roster under state personnel law. Section 1324a(a)(2) prohibits continuing to employ-an active verb that contemplates an ongoing exchange of labor for compensation. Simply maintaining someone's name on a roster or preserving her eligibility to return is not "employing" her during the leave period, so long as the city ensures zero work and zero pay.
    Is it as clean as a full termination? No-Professor Ruser is right that this carries marginally more analytical risk. But the Ninth Circuit endorsed this exact approach in Incalza v. Fendi, 479 F.3d 1005 (9th Cir. 2007), no court has held that unpaid leave violates § 1324a(a)(2), and DHS has never issued guidance requiring termination over leave. Given that the city wants to retain a good employee and preserve her benefits, the unpaid leave approach is the right balance of legal defensibility and practical good sense.
    Professor Ruser's suggestion about a Congressional inquiry is excellent and should be pursued immediately. If you have not dealt with them in the past the process requires  that the employee should contact her U.S. Representative's office (or either Nebraska Senator), sign a privacy release, and provide the USCIS receipt number along with a letter from the city explaining the imminent EAD expiration and risk of job loss.

    George Achola
    Attorney at Law |
    Communitas – Law & Economic Development Group

    10404 Essex Court, Suite 101, Omaha, NE 68124
    Phone: 402-503-8100 | Email:
    GAchola@communitaslaw.com

    Fortitudine Vincimus -Through endurance, we conquer.

    This email and any attachments may contain confidential and privileged information intended only for the named recipient. If you are not the intended recipient, please notify the sender and delete this message.​