Alaska Supreme Court
Arctec Services, an Asrc Company, and Asrc Service Center, Appellants v. Gayle Cummings, Appellee
March 8, 20132013 Alas. LEXIS 22
Summary
The court held that the word "knowingly" in the workers’ compensation fraud statute requires a subjective intent to defraud, not an objectively reasonable belief standard. Because the Board found Cummings credible when she testified that she regarded her herb-store activities as voluntary and not reportable employment, that credibility determination established that she did not knowingly make a false statement. The court therefore affirmed the Commission’s decision, though on a different ground from the Commission’s causation analysis.