First, the detected resources in order of appearance:
1. Form I-9, Employment Eligibility Verification (USCIS)
2. E-Verify (uscis_resource)
3. H‑2A (policy)
I have added up to one verified .gov link for each resource at its first mention in the article body, preserving all content and formatting exactly and not changing any existing links.

(SOUTH DAKOTA) Immigration audits targeting dairy farms in South Dakota and Texas intensified in 2025, forcing multiple operations to cut large parts of their workforce after federal I-9 audits uncovered problems. Industry groups say the sudden enforcement pace, combined with the 10 days employers get to terminate flagged workers, has created immediate labor crises on farms that run 24/7 and depend heavily on immigrant labor.
At least one South Dakota dairy was required to terminate nearly 40 workers following an audit. In Texas, at least nine dairies received I-9 audits over a single weekend in July 2025, according to producers tracking the sweep. Managers describe the current climate as “an employees job market, not an employer’s job market,” which means even short-term losses can cascade into missed milkings, stressed herds, and overtime that remaining crews can’t sustain for long.
Audit sweep: what inspectors look for and immediate impacts
Federal checks focus on whether employers have properly completed Form I-9, Employment Eligibility Verification (USCIS) for every hire and whether workers are authorized to work. Audits also compare employer records with the E-Verify system, which can flag mismatches.
- When auditors identify problems, employers receive 10 days to correct record issues or terminate affected workers.
- For labor-heavy dairy farms, losing dozens of employees in days is not a policy footnote; it is a direct threat to daily operations, milk supply, and animal care.
Employers must use Form I-9 to confirm a worker’s identity and work permission at hire. The official form and instructions are available here: Form I-9, Employment Eligibility Verification (USCIS).
Producers say they’re doing their best to follow the rules, but a wave of I-9 audits across two states all at once is different from routine compliance checks. Dairy barns can’t pause—cows must be milked multiple times a day, animals must be fed, and calves still need care.
In an unexpected turn, at least one South Dakota dairy that had fired nearly 40 workers after an audit received authorization to rehire those workers. The farm’s attorney secured an order allowing reinstatements, according to people familiar with the case. It’s unclear whether that single outcome reflects a broader shift in federal enforcement policy or is limited to the facts of that operation.
Producers in both states say they still don’t know why South Dakota and Texas were pinpointed for the heaviest audit activity.
The human ripple effects show up quickly in rural communities. Many dairy workers live on or near the farms, and families can lose housing and steady income overnight.
Remaining staff face increased mental and physical strain, often stretching to cover double shifts. Advocates warn that hurried terminations can also push workers—authorized and unauthorized alike—into the shadows, making it harder for good employers to keep stable teams.
Industry fallout and policy debate
Producers argue the E-Verify system has problems and call it “flawed.” Their key point: confirming a person’s legal status should be handled by the federal government, not by small businesses that lack investigative tools.
Key industry data cited:
- The National Milk Producers Federation estimates that more than half of all U.S. dairy labor comes from immigrant workers.
- Nationwide, roughly 40–43% of dairy workers are undocumented.
As one industry leader put it, “dairy farms will not be able to survive, let alone thrive, without a steady, reliable workforce.”
Producers warn that sudden losses of trained staff threaten:
- Animal welfare — milking routines, herd health checks, and calving support require skilled hands.
- National food security — milk is a base ingredient for cheese, yogurt, butter, and infant formula.
They compare the current disruptions to the supply shocks during the pandemic, when a handful of broken links led to empty shelves.
These immigration audits come as Homeland Security Secretary Kristi Noem, the former South Dakota governor, has pledged to use “all her authority to enforce immigration laws” and employ “every single one” of the department’s “broad and extensive” powers. Producers say they support lawful hiring but want clear, consistent rules—and enough time—to comply without breaking their businesses.
Proposed policy solutions and political context
The dairy sector is pressing Congress to adapt the H‑2A program so year-round operations like dairies can hire legal guest workers. Currently, H‑2A is designed around seasonal jobs, which does not fit year-round dairies.
- Industry officials say proposals to allow year-round H‑2A hiring have gained traction.
- They’re hopeful reforms “maybe have a shot here at solving this problem for the first time in 20 plus years,” especially with public support from President Trump for agricultural labor program changes.
According to analysis by VisaVerge.com, bipartisan interest in targeted fixes has grown as more districts feel the strain of labor shortages in food production.
Practical compliance steps for farm owners
Legal and compliance advisors suggest these actions for farms facing I-9 audits:
- Conduct a good-faith internal review of recent Form I-9 files and correct technical errors promptly.
- Train hiring staff on identity documents and recordkeeping; keep copies of documents only if applied consistently to all hires.
- Avoid unfair documentary practices; don’t ask for extra papers from workers who “look foreign.” That can lead to discrimination claims.
- If you receive a government notice, respond on time, document every step, and consult counsel about timelines and options.
- If an E-Verify tentative nonconfirmation occurs, give the worker the chance to contest it. Terminate only after a final nonconfirmation or official directive.
Broader supply-chain and community consequences
Dairy co-ops and processors are bracing for knock-on effects:
- If member farms can’t keep shifts covered, milk collection routes may change and plants could face uneven supply.
- Retail buyers are already asking about stability heading into the holiday production cycle, when demand for butter and cheese typically rises.
Local officials in rural counties are trying to balance federal enforcement with community stability:
- School districts worry about students if parents lose jobs and move suddenly.
- Hospitals and clinics worry about disruptions to employer-sponsored coverage.
- County boards want clarity on whether the intense audit focus will broaden beyond South Dakota and Texas, or whether the summer sweep was a one-off.
What to watch next
What happens next will turn on three fronts:
- Whether the Department of Homeland Security issues clearer guidance on audit procedures and timelines.
- Whether Congress advances H‑2A adjustments to cover year-round dairy farms.
- Whether courts see more challenges like the South Dakota reinstatement case.
For now, farm owners are preparing for more files to be checked and more questions to be asked—while cows still need to be milked tomorrow morning.
This Article in a Nutshell
In 2025 I-9 audits intensified in South Dakota and Texas, leading to rapid terminations that strained dairy operations reliant on immigrant labor. Auditors review Form I-9 records and cross-check E-Verify, giving employers only 10 days to cure issues or dismiss affected staff. One South Dakota dairy fired nearly 40 workers and later secured a legal order to reinstate them, raising questions about consistency in enforcement. Producers warn that sudden labor losses jeopardize milking schedules, animal welfare, and supply chains. The industry is pushing congressional fixes to allow year-round H-2A hiring and improvements to E-Verify. Farms should conduct internal I-9 reviews, train hiring staff, document government responses, and consult legal counsel during audits.
 
					
 
		 
		 
		 
		 
		 
		 
		 
		 
		 
		 
		