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