In Talukdar v. U.S. Department of Veterans Affairs, a Department of Labor (DoL) administrative law judge decided that the Department of Veterans Affairs Medical Center (VAMC) in Fargo, North Dakota, violated whistleblower protection provisions under the Immigration and Nationality Act (INA) when it fired two physicians for their participation in DoL investigations of the VAMC’s implementation of its H-1B visa program. No. 2002-LCA-00025 (Dep’t Labor Apr. 12, 2004). The INA’s employee protection provisions are similar in language and intent to nuclear and environmental whistleblower statutes. 8 U.S.C.