Claim of Amoah v. Mallah Management, LLC
An undocumented claimant, who secured employment using fraudulent documents, was injured and initially received workers' compensation benefits. After revealing his true identity, the employer's carrier contested the benefits, leading to an appeal. The court affirmed the Workers' Compensation Board's decision, which held that the claimant's use of fraudulent documentation did not preclude the award of wage replacement benefits under state law. The decision distinguished the U.S. Supreme Court's ruling in Hoffman Plastic Compounds v NLRB, finding no preemption by IRCA because denying benefits would contradict IRCA's primary goal of deterring employers from hiring undocumented workers and would not compel the claimant to commit future violations. The court concluded that New York's Workers' Compensation Law does not conflict with federal immigration policy in this context.