Claim of Vanostrand v. Felchar Manufacturing Corp.
The case involves an appeal from a Workers’ Compensation Board decision concerning a claimant found to have defrauded employers and carriers by overstating mileage and making false statements about her physical condition. The Board ruled that Workers’ Compensation Law § 114-a, which bars future wage replacement benefits for such violations, does not preclude the claimant from receiving future mileage expenses or medical coverage. The Appellate Division, Third Department, affirmed this decision, citing its previous ruling in Matter of Rodriguez v Burn-Brite Metals Co., which established that the penalties under Workers’ Compensation Law § 114-a are limited to wage replacement benefits and do not extend to medical benefits. The court also found no error in the Board's tacit refusal to require the claimant to directly repay the mileage overpayments to the subject carriers.