Ridgeway v. RGRTA Regional Transit Service
A bus driver (claimant) had existing workers’ compensation claims. In October 2005, she was involved in a car accident after her shift ended. On a personal injury form for her self-insured employer, she incorrectly indicated the accident occurred during her work shift. The employer argued this was a material misrepresentation under Workers’ Compensation Law § 114-a, seeking to bar her from further benefits for both March and October 2005 injuries. A Workers’ Compensation Law Judge initially agreed. However, the Workers’ Compensation Board later rescinded this decision, determining there was insufficient evidence to prove the claimant knowingly made material misrepresentations. The employer appealed this ruling. The appellate court affirmed the Board's decision, finding substantial evidence—including the claimant's testimony about filling out the form a day later while upset, the form's ambiguity, and her subsequent clarification to the employer—to support the conclusion that she did not knowingly make a false statement.