Matter of Vazquez v. Skuffy Auto Body Shop
Luis Vazquez, an auto body technician, sustained a work-related back injury in 2013 and received workers' compensation benefits. His benefits were suspended in November 2015, and upon his application for reinstatement, the carrier alleged a violation of Workers' Compensation Law § 114-a due to undisclosed work for a landscaping business. Initially, a Workers' Compensation Law Judge found no violation, but the Workers' Compensation Board reversed this decision, determining that Vazquez knowingly made material misrepresentations about his return to work and was subject to mandatory disqualification of benefits from April 25, 2016, to December 28, 2016, and future indemnity benefits after December 29, 2016. The Appellate Division, Third Department, affirmed the Board's decision, finding substantial evidence supported the Board's determination that Vazquez violated Workers' Compensation Law § 114-a by making false representations and omissions regarding his work activity to obtain benefits. The court also found no abuse of discretion in the Board's imposition of a penalty disqualifying him from future indemnity benefits, citing a pattern of deceit.