Claim of Borgal v. Rochester-Genesee Regional Transportation Authority
In January 2009, the claimant sustained work-related injuries to his left shoulder and right hand, leading to total temporary disability benefits after undergoing shoulder surgery in July 2009. An MRI in August 2010 revealed a retearing of the rotator cuff. The self-insured employer initiated surveillance and alleged that the claimant violated Workers’ Compensation Law § 114-a by misrepresenting his work activities and the extent of his disability on benefits questionnaires. However, a Workers’ Compensation Law Judge and subsequently the Workers’ Compensation Board found that the claimant had not violated the law. The Appellate Division affirmed this decision, concluding that there was substantial evidence to support the Board's determination, noting that the claimant's minimal renovation-related activities did not constitute work for the purpose of misrepresentation and that medical opinions supported his reported disability level.