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CALEDA L. WOODS VS. BOARD OF REVIEWÂ (BOARD OF REVIEW, DEPARTMENT OF LABOR)
A-1865-15T1
N.J. Super. Ct. App. Div.
Jun 23, 2017
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Background

  • Appellant Caleda Woods received unemployment benefits after losing her job in 2005 and repeatedly renewed claims through 2010.
  • Over several years she worked for multiple employers (including SDH Education East and Able Medical) but failed to accurately report or underreported her weekly wages to the Division.
  • The Division audited Woods’s claims, cross-referenced employer payroll reports, and found substantial discrepancies; it concluded she misrepresented wages and sought recovery.
  • The Division demanded repayment of $21,041 in overpaid benefits, imposed fines/penalties of $6,020.75, and imposed a one-year disqualification from benefits.
  • An Appeal Tribunal and then the Board of Review sustained the Division’s determinations (with specified corrections), and Woods appealed to the Appellate Division.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Woods must repay full overpayments despite partial work eligibility Woods: she worked part-time and would have qualified for partial benefits, so repayment should be reduced Division: statute requires full repayment when benefits were received while not entitled Court: Affirmed full repayment; Malady controls — misreporting precludes reduction
Whether fines/penalties should be waived for equity or hardship Woods: severe financial hardship, single mother of six; requests waiver Division: waiver limited and precluded if claimant misrepresented material facts; waiver not sought from Director Court: Waiver unavailable absent Director review and where misrepresentation exists
Whether Division's wage/period findings were inaccurate Woods: disputes some periods/amounts (e.g., claims she was unemployed May–Dec 2010) Division: employer payroll and audit records support amounts and periods Court: Board’s factual findings supported by record; challenges rejected
Whether the Board’s decision was arbitrary/capricious Woods: asks relief from obligation generally Division: substantial evidence supports Board’s decision and statutory scheme Court: Standard of review defers to Board; decision affirmed as reasonable

Key Cases Cited

  • Malady v. Bd. of Review, 76 N.J. 527 (1978) (full repayment required despite eligibility for partial benefits where claimant misreported wages)
  • Brady v. Bd. of Review, 152 N.J. 197 (1997) (standard of appellate review of Board factual findings and deference to agency credibility determinations)
  • Bannan v. Bd. of Review, 299 N.J. Super. 671 (App. Div. 1997) (statutory policy requires full repayment of improperly received unemployment benefits)
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Case Details

Case Name: CALEDA L. WOODS VS. BOARD OF REVIEWÂ (BOARD OF REVIEW, DEPARTMENT OF LABOR)
Court Name: New Jersey Superior Court Appellate Division
Date Published: Jun 23, 2017
Docket Number: A-1865-15T1
Court Abbreviation: N.J. Super. Ct. App. Div.