United States v. Abdur Tai

750 F.3d 309, 2014 WL 1687814, 2014 U.S. App. LEXIS 8129
CourtCourt of Appeals for the Third Circuit
DecidedApril 30, 2014
Docket13-1998
StatusPublished
Cited by38 cases

This text of 750 F.3d 309 (United States v. Abdur Tai) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Abdur Tai, 750 F.3d 309, 2014 WL 1687814, 2014 U.S. App. LEXIS 8129 (3d Cir. 2014).

Opinion

OPINION

SHWARTZ, Circuit Judge.

Defendant Abdur Razzak Tai appeals his conviction and sentence for mail and wire fraud in connection with claims for payment from the Fen-Phen Settlement Trust. Tai argues that the District Court committed plain error by implicitly shifting the burden of proof in its “willful blindness” jury instruction and applying upward adjustments under the advisory Sentencing Guidelines for abuse of a position of trust, use of a special skill, and aggravated role. For the reasons set forth below, we conclude that the District Court’s jury instruction and its upward adjustments based upon position of trust and special skill were not in error, but we will remand to enable the District Court to make the required factual findings concerning whether Tai supervised a criminally culpable subordinate, which is necessary to award an aggravated role enhancement.

I

In the late 1990s, individuals who had taken the prescription diet-drug combination commonly known as Fen-Phen began filing lawsuits against American Home Products Corporation (“AHP”), the predecessor of Wyeth, claiming that the drugs caused valvular heart disease. In 2000, the United States District Court for the *312 Eastern District of Pennsylvania approved a class action settlement (the “Settlement”), which included the establishment of the Fen-Phen Settlement Trust (the “Trust”), through which Wyeth paid compensation to class members who demonstrated that they sustained valvular heart damage.

Financial compensation for these heart conditions was determined under a preestablished matrix. 1 To receive compensation, claimants were required to provide a recording of and a physician’s report about an echocardiogram (“echo”) 2 and a document referred to as a “Green Form” 3 signed by a board-certified cardiologist or cardiothoracic surgeon with Level 2 training in echocardiography. 4 The Trust then reviewed the submissions and, when appropriate, tendered payment.

A representative of the Trust explained that the Trust relied on the integrity of the physicians signing the reports and Green Forms to ensure that the claimants actually had heart conditions that were covered by the Settlement. Both the Trust and Wyeth had “audit rights,” which allowed them to have highly trained, board-certified physicians review the materials, submitted to ensure “the tape ... matche[d] with the rest of the substantiation.” App. 87. Under the original terms of the Settlement, only 15% of all claims could be audited. In November 2002, the District Court ordered that 100% of the claims would be subject to audit because of concerns about the bona fides of the claims being submitted. 5

Attorneys who represented certain FenPhen claimants retained Tai, a board-certified and Level 2-qualified cardiologist, to read echoes and prepare reports to submit to the Trust. Tai estimated that he read 12,000 echoes for this purpose, and asserted that he was owed over $2 million dollars for the services he provided. This amount was based upon a fee for each echo read and a bonus payment for each approved payment. 6 Most of the Green Forms Tai signed were submitted before the 100% audit rule was imposed.

Tai acknowledged to law enforcement that in about 10% of the cases, he dictated physician’s reports consistent with the findings in the technicians’ reports despite knowing that the measurements were wrong. He also admitted that he had his technician and office manager, Debbie Patrick, review about 1,000 of the echoes be *313 cause he did not have the time to do the work himself. Patrick testified, via deposition, that she reviewed “a couple hundred” echoes, App. 605, and provided Tai with her notes to “help him out” with the volume of echoes he was asked to review. App. 589-90. Patrick testified that she did not know whether Tai read the echoes himself before signing the physician’s report and Green Form, but she “would assume that he did because there were several times that [she] even asked him” if he agreed with her conclusions and he sometimes told her she was wrong. App. 591— 92. For one particular lawyer representing Fen-Phen claimants, Tai signed more than 1,400 Green Forms, and of the 1,173 of those Green Forms that were audited or reviewed, only 109 were approved. A government expert reviewed a nonrandom sample of the forms Tai submitted for this attorney and found that, in a substantial number of the cases, the measurements were not only clearly incorrect, but were actually inconsistent with a human adult heart. 7

Tai was charged in a thirteen-count indictment for mail and wire fraud, in violation of 18 U.S.C. §§ 1341 and 1343, respectively. The jury found Tai guilty of all charges, and he was sentenced to concurrent sentences of 72 months’ imprisonment 8 and three years’ supervised release, and ordered to pay restitution of $4,579,663, a fine of $15,000, and a special assessment of $1,300. Tai appeals.

II 9

The parties agree that none of the issues Tai presents were preserved for appeal and that plain error review applies. 10 United States v. Couch, 291 F.3d 251, 252-53 (3d Cir.2002) (stating that where no objection to the Guidelines calculation was preserved at sentencing, it is reviewed for plain error); United States v. Antico, 275 F.3d 245, 265 (3d Cir.2001) (reviewing a jury instruction for plain error where the challenge on appeal was not raised at trial); Fed.R.Crim.P. 30(d), 52(b). The defendant bears the burden to establish plain error. United States v. Olano, 507 U.S. 725, 734-35, 113 S.Ct. 1770, 123 L.Ed.2d 508 (1993). For reversible plain *314 error to exist, there must be (1) an error; (2) that is plain; (3) that affects substantial rights; and (4) which seriously affects the fairness, integrity, or public reputation of judicial proceedings. Johnson v. United States, 520 U.S. 461, 466-67, 117 S.Ct. 1544, 137 L.Ed.2d 718 (1997).

Ill

A. Jury Instruction

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Fuquan Hill
Third Circuit, 2026
United States v. Gary Frank
Third Circuit, 2023
Jane Doe v. Manor College
Third Circuit, 2023
United States v. Sharif El-Battouty
38 F.4th 327 (Third Circuit, 2022)
United States v. Steven Metro
882 F.3d 431 (Third Circuit, 2018)
United States v. Kenneth Karow
Eleventh Circuit, 2018
United States v. Adolphus Nwokedi
710 F. App'x 91 (Third Circuit, 2017)
United States v. Benjamin Easley
703 F. App'x 135 (Third Circuit, 2017)
United States v. Ralph Miller
695 F. App'x 666 (Third Circuit, 2017)
United States v. Dwayne Onque
665 F. App'x 189 (Third Circuit, 2016)
United States v. DeShawn King
661 F. App'x 150 (Third Circuit, 2016)
Coleman v. Commonwealth Land Title Insurance Co.
318 F.R.D. 275 (E.D. Pennsylvania, 2016)
United States v. Michael Calabretta
831 F.3d 128 (Third Circuit, 2016)
United States v. Michael Bernick
651 F. App'x 102 (Third Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
750 F.3d 309, 2014 WL 1687814, 2014 U.S. App. LEXIS 8129, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-abdur-tai-ca3-2014.