California v. Hamilton

A jury convicted former United States Postal Service employee Robert Hamilton of three counts of making a false or fraudulent statement for the purpose of obtaining compensation under the California workers' compensation law. On appeal, Hamilton argued: (1) because, as a federal employee, his workers' compensation benefits were provided under the Federal Employment Compensation Act, the doctrine of federal preemption barred him from being prosecuted under California law for any offense alleging fraud in obtaining federal workers' compensation benefits under FECA; and (2) regardless of whether the prosecution was preempted, his conviction was supported by insufficient evidence under Insurance Code section 1871.4 (a)(1) because that statute applied only to false or fraudulent statements made for the purpose of obtaining compensation afforded under the California workers' compensation law, which was not applicable to him as a federal employee. On the issue of federal preemption, the Court of Appeal concluded that Hamilton did not meet his burden to establish that the State's prosecution of him was preempted. With respect to the sufficiency of the evidence, the Court agreed with the State's concession that insufficient evidence supported Hamilton's convictions because he did not receive compensation under the California workers' compensation law. The Court declined to exercise discretion to modify the judgment to impose convictions on a lesser included offense. Accordingly, the judgment was reversed. View "California v. Hamilton" on Justia Law