“The general consensus among immigration attorneys was that this was a hopelessly recurring problem and there was little to be done,” says Zetoony, an associate in Bryan Cave’s Washington, D.C., office. “But I do a lot of consumer protection work, and the first thing that occurred to me was that there are laws out there to stop fraud and deceptive practices.”

Zetoony found that past enforcement efforts had been left largely to state attorneys general, many of whom had been wary of such a politically sensitive issue. And immigration lawyers hadn’t employed the consumer protection angle; they assumed that the only recourse was to report notarios to state bar associations for an unauthorized practice of law.