Inalfa Roof Systems has a significant presence in the United States, with multiple manufacturing facilities and engineering centers supporting the North American automotive market. The company operates major plants in Michigan and Georgia, where it produces sunroofs and panoramic roof systems for leading automakers, including Ford, General Motors, and Stellantis. Inalfa is owned by Beijing Hainachuan Automotive Parts Co., Ltd. (BHAP), a subsidiary of the BAIC Group, one of China’s largest state-owned automotive manufacturers.
Sharon McKay, an employee at the company, sustained two separate workplace injuries in 2021. The case primarily focused on the second injury, which occurred on September 14, 2021. McKay had originally been hired in late 2020 as an assembly operator, a physically demanding job requiring significant lifting, standing, and mobility.
As part of her hiring process, McKay underwent a physical examination and completed a medical questionnaire. She denied any prior injuries despite having suffered a severe four-wheeler accident in 2012 that resulted in multiple fractures, a dislocated shoulder, and a spinal injury. Inalfa later relied on this questionnaire to assess her fitness for the job.
On June 11, 2021, McKay suffered a back injury at work, which aggravated her prior condition. She was taken to the hospital and remained out of work until September 9, 2021. During her recovery, she informed her employer about her past injuries, including the 2012 accident. Despite this revelation, Inalfa allowed her to return to work in the same position.
Just five days later, on September 14, McKay suffered another injury while reaching for a part on the assembly line. The company contested her workers’ compensation claim for this second injury, arguing that McKay had fraudulently concealed her past medical history when she was hired.
At the heart of the case was the Rycroft defense, a legal precedent from a 1989 Georgia Supreme Court ruling. The Rycroft defense allows an employer to deny workers' compensation benefits if three conditions are met:
Inalfa successfully used this defense to argue that McKay’s original June 11 injury should not qualify for workers’ compensation because she had not disclosed her previous back injury. The State Board of Workers’ Compensation agreed with Inalfa, and the superior court upheld the decision.
However, McKay appealed, arguing that the Rycroft defense should not apply to her second injury on September 14. By that time, Inalfa knew about her past injuries and had still allowed her to continue working.
The Georgia Court of Appeals ruled in McKay’s favor, stating that once an employer learns of an employee’s misrepresentation and chooses to retain them, they waive the right to use the Rycroft defense for future injuries.
Judge Christopher McFadden, writing for the court, emphasized that an employer’s continued employment of an individual after learning of a false statement effectively nullifies their ability to later claim they were misled. The ruling aligns with broader legal principles that fraudulent contract defenses must be invoked immediately, rather than selectively applied when it benefits one party.
“Inalfa’s willingness to retain McKay in the assembly operator position, after learning of her prior back injury and false representation about it, waives its right to use the Rycroft defense to deny McKay workers’ compensation benefits for the subsequent injury she suffered,” the court wrote.
The decision reverses the lower court’s ruling and affirms that McKay is entitled to workers’ compensation benefits for her September 14, 2021, injury.
The ruling has significant implications for both employers and employees in Georgia. It sets a precedent that employers must act upon discovered misrepresentations promptly rather than continuing employment and later using those misrepresentations as grounds to deny benefits.
Legal experts believe this decision will limit the use of the Rycroft defense in cases where an employer is aware of a worker’s past injuries but allows them to continue working. This shift reinforces the core principle of workers' compensation law: that employees injured on the job should receive benefits regardless of prior medical history unless there is clear and immediate employer reliance on false information at the time of hiring.
With the ruling now established as precedent, similar cases may see courts taking a more employee-friendly approach to workers' compensation eligibility when past misrepresentations are later disclosed and acknowledged by an employer.
