United States v. David Suetholz

CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 13, 2024
Docket23-5613
StatusUnpublished

This text of United States v. David Suetholz (United States v. David Suetholz) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. David Suetholz, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0387n.06

No. 23-5613 FILED UNITED STATES COURT OF APPEALS Sep 13, 2024 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY DAVID W. SUETHOLZ, ) Defendant-Appellant. ) ) OPINION )

Before: GRIFFIN, NALBANDIAN, and BLOOMEKATZ, Circuit Judges.

GRIFFIN, Circuit Judge.

A jury convicted defendant David Suetholz, M.D., of unlawfully prescribing opioids,

benzodiazepines, and other controlled substances to patients in violation of 21 U.S.C. § 841. On

appeal, Suetholz challenges various aspects of his trial, including the sufficiency of the evidence,

jury instructions, evidentiary rulings, and the government’s belated disclosure of impeachment

evidence. We reject these challenges and affirm his convictions.

I.

A.

Beginning in 1975, defendant David Suetholz practiced medicine in Covington, Kentucky.

His prescribing practices eventually came under the scrutiny of the Kentucky Board of Medical

Licensure, and an investigation resulted in a 2012 agreed order highlighting problems with his

prescribing. By signing that order, Suetholz stipulated that the Board could find that he had No. 23-5613, United States v. Suetholz

violated Kentucky medical rules that protect against patient harm. He acknowledged the Board’s

findings that his patient files contained “inadequate documentation” of patients’ chronic pain to

“support the medical necessity of prescribing controlled substances,” and that he failed to adjust

prescriptions to account for his patients’ problematic behaviors, such as seeking early refills or

reportedly selling prescription drugs.

Although Suetholz “denie[d] any violation” of Kentucky medical regulations, he agreed to

several sanctions, including a three-month ban on prescribing controlled substances, a requirement

to log his prescriptions when he resumed prescribing, and recurring review of his patient charts by

the Board. Reviewers identified shortcomings in how Suetholz documented his medical decision-

making related to prescribing controlled substances, noting that his patient charts lacked detail on

the risk of opioid abuse and consideration of the results of urine drug screens. Following the

order’s requirements, Suetholz took remedial training courses to improve how he documented his

medical decision-making. After Suetholz completed the Board’s requirements, the Board released

him from the order in August 2014.

But soon after, Suetholz’s prescribing practices again deviated from professional standards

for at least three patients: LP, DK, and WY.1

LP

Suetholz started prescribing controlled substances to LP in 2015. Rachelle Guenther,

Suetholz’s patient and LP’s romantic partner, referred LP to Suetholz. Guenther informed

Suetholz about LP’s history of addiction to alcohol and heroin, including that LP had previously

undergone addiction treatment. Nevertheless, Suetholz prescribed LP opioids for unspecified foot,

1 Following the convention of the district court and the parties, we refer to Suetholz’s patients whose prescriptions formed the basis of the charges by their initials. -2- No. 23-5613, United States v. Suetholz

back, mouth, and shoulder pain and benzodiazepines for reported panic attacks. In LP’s patient

record, Suetholz neither documented LP’s addiction history, nor explained why LP’s vague pain

descriptions justified recurring prescriptions for opioids, nor elaborated a psychiatric justification

for prescribing benzodiazepines.

In May and July 2018, LP tested negative for the benzodiazepines that Suetholz had

prescribed. Such negative results are problematic because, if the patient is taking medication

appropriately, urine should contain traces of the prescribed medications. Instead, these results

indicated a risk that LP was dangerously overtaking medications and running out before the

urine drug test. Yet Suetholz neither addressed the failed drug tests in LP’s patient file nor altered

LP’s prescriptions. Soon after, in September 2018, Suetholz prescribed LP tramadol and

alprazolam (generic Xanax). And he wrote a prescription for alprazolam in May 2019.

LP died of a heroin overdose in June 2019, and Guenther informed Suetholz about

LP’s death soon after.

DK

Despite learning that one of his patients had died of an opioid overdose, Suetholz continued

prescribing dangerous controlled substances to patients who showed signs of drug abuse. One of

those patients was DK.

During DK’s initial visit to Suetholz’s clinic, DK tested positive for benzodiazepines, yet

DK’s patient record contains no evidence that Suetholz screened DK for addiction issues. Suetholz

instead prescribed DK benzodiazepines and proceeded to increase the prescription by a “shocking”

amount (from 15 to 120 pills per prescription) in future visits. He also did not document why

DK’s reported generalized anxiety justified such a high dose of benzodiazepines instead of a lower

dose or a less dangerous substance.

-3- No. 23-5613, United States v. Suetholz

In February 2021, DK died of a drug overdose. Coincidentally, Suetholz served as the

county coroner where DK died. His office concluded that the death resulted from a combination

of opioids and the same benzodiazepine that Suetholz prescribed to DK.2

WY

Still, Suetholz did not reevaluate his dangerous prescribing practices. For patient WY,

Suetholz wrote prescriptions for 80-milligram Oxycontin pills, “the strongest pill size that you can

get in Oxycontin.” Suetholz prescribed WY three of these pills per day, resulting in a “quite high”

daily morphine milligram equivalent (MME) value of 360. Suetholz ignored WY’s inconsistent

urine drug tests, and he did not monitor WY’s claimed chronic pain to justify his prescribing. And

rather than order new imaging to diagnose WY’s complaints of pain, Suetholz relied on 15-year-

old imaging.

B.

A superseding indictment charged Suetholz with 25 counts of illegal distribution of

controlled substances under 21 U.S.C. § 841. Each count was for a specific prescription—for

opioids, benzodiazepines, or other controlled substances—that Suetholz wrote between September

2018 and August 2021. Among other patients’ prescriptions, LP’s, DK’s, and WY’s prescriptions

formed the bases for the indictment.

After a five-day trial, the jury convicted Suetholz on 12 of the 25 counts—those that related

to LP, DK, and WY. Suetholz moved for judgment of acquittal and for a new trial, which the

district court denied. The district court then imposed a below-Guidelines sentence of twelve

months and one day of imprisonment. This appeal followed.

2 The government did not charge Suetholz with a resulting-in-death enhancement under 21 U.S.C. § 841. -4- No. 23-5613, United States v. Suetholz

II.

Suetholz first argues that there was insufficient evidence for his convictions. A

sufficiency-of-the-evidence challenge must fail if “a rational jury could have found the elements

of the crime beyond a reasonable doubt.” United States v.

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