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Attorneys owe absolute duties of loyalty and confidentiality to their
clients. Problems arise, however, when there is a conflict of interest. Such
conflicts arise when attorneys have separate clients with conflicting
interests. This situation very commonly arises when an attorney represents
both an employer and employee.
In most situations, having a single attorney represent both the employer and
employee is a valid decision. Using a single attorney saves both time and
money. It is only when the employer and employee have competing interests
that problems arise. In such situations, an attorney may not favor one side
over the other. Similarly, an attorney may not continue to represent a party
while withholding important information from that party.
Often, an attorney will be hired by an employer to perform services for the
company and the employee becomes a third party beneficiary. Whether this
creates a duty by the attorney to the foreign national employee depends on
the unique facts of the case. Did the attorney receive confidential
information from the employee? Did the attorney submit a formal notice of
appearance as attorney of record (form G-28) on behalf of the employee?
These and other questions are critical to determining the duty an attorney
owes an employee.
To the extent that an attorney learns something from an employee, and the
employee has an expectation of confidence, the attorney may not disclose
that information to an employer or any other third party. If this violates
the attorney’s duty to the employer, then the attorney must withdraw from
representation of both.
The specific work that an attorney does frequently determines the duty the
attorney owes the employee. For example, the filing of a labor certification
(PERM) or an immigrant preference petition (I-140) generally do not involve
the need to obtain confidential information from the foreign national
employee. These filings “belong” to the employer, in the sense that they may
only be filed and prosecuted by employers, without any intervention by the
employee.
An application for adjustment of status, however, is entirely personal to
the employee. The employer may not control when or how such applications are
filed, nor may an employer demand that an application for adjustment of
status be withdrawn. To the extent that an attorney prepares and files an
application for adjustment of status, the attorney represents the foreign
national employee only. The attorney may not take any actions adverse to the
employee’s interests in this regard. The attorney is also obligated to
provide the adjustment of status applicant with a complete copy of the
application, as well as copies of any and all communications to and from the
USCIS concerning the case.
The law permits an applicant for adjustment of status with a case that has
remained unadjudicated for more than 180 days to change jobs, employers, or
both without losing eligibility to use the I-140 filed by the sponsoring
employer. The only limitation being that the new job must be in “the same or
similar occupational classification.”
Some employers, upon learning that an employee has used this provision to
change jobs will instruct their attorneys to withdraw the I-140 petition
previously filed. Under current law, this is not possible. There is no legal
or practical requirement that obligates an employer to attempt to withdraw a
previously filed I-140 petition under such circumstances.
An attorney asked to file a withdrawal request for a previously filed I-140
is presented with a clear conflict of interest if that same attorney filed
an application for adjustment of status for the employee. By filing an I-140
withdrawal request, the attorney is taking an action that could prejudice
the interests of the employee. While employers have no legal right to
withdraw I-140 petitions that accompany adjustment of status applications
that have been pending more than 180 days, some rogue CIS adjudicators will
nonetheless use such action as a basis for improperly denying an application
for adjustment of status. These types of denials are easily reversed through
the filing of a motion to reconsider, but that does not compensate for the
time, expense, and worry that the applicant goes through in the time it
takes to process the MTR.
Of greater concern to most applicants who change jobs while still
“represented” by the employer’s attorney is the question of what will happen
to their pending adjustment of status application? That is, will the
employer’s attorney continue to vigorously pursue an approval? What happens
if an RFE is issued? How difficult will it be to get information from the
former employer’s attorney?
These are all legitimate questions. Any employee who changes jobs, but
continues to be represented by the former employer’s attorney needs to
clarify certain issues with his or her attorney of record. For example, if
directed by the employer to withdraw an I-140 in a case where an adjustment
of status application has been pending for more than 180 days, will the
attorney do this? Will the attorney notify the employee of all
communications between the attorney and the USCIS, including requests for
evidence (RFE), notices of intent to deny (NOID), and routine case status
inquiries? Will the attorney respond to RFEs and NOIDs on behalf of the
employee? Has the attorney provided the employee with a complete copy of the
case file to date, including copies of all communications to and from the
USCIS involving the employee?
There is nothing wrong with continuing to use the services of a former
employer’s attorney, provided the applicant has an understanding with the
attorney as to these issues.