Victor Shehata, Appellant v. Salvation Army and Northern Adjusters, Appellees

Summary

The court held that reimbursement for fraudulently obtained workers' compensation benefits requires a causal link between the employee's knowingly false statement and the benefits received. Because Shehata made no false statement before October 14, he could not be ordered to repay benefits paid earlier, although the record supported reimbursement for one later week. The court also held that silence was not a statutory representation absent an applicable duty to disclose and that the appeal-related attorney-fee award was an abuse of discretion.