United States v. Elizabeth Hernandez

Court of Appeals for the Eleventh Circuit·Decided July 31, 2026·No. 24-10047·Published

Opinion

FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-10047 ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

ELIZABETH HERNANDEZ, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:22-cr-20152-KMM-1 ____________________

Before JILL PRYOR, LUCK, and BRASHER, Circuit Judges. BRASHER, Circuit Judge: This appeal is about procedural fairness at trial. The govern- ment charged nurse practitioner Elizabeth Hernandez with de- frauding Medicare to the tune of $111 million. Specifically, the gov- ernment alleged that Hernandez prescribed unnecessary medical 2 Opinion of the Court 24-10047

equipment and genetic testing, and that she billed for fraudulent and nonexistent telemedicine appointments. After a six-day trial, a jury convicted Hernandez of Medicare fraud. Hernandez argues that her trial was unfair in several re- spects. Most significantly, she challenges the district court’s deci- sion to grant the government ten more minutes for closing argu- ment than it allotted to her. Although district courts have broad discretion to set the total amount of time for closing arguments— and although this discretion extends to allocating that time be- tween the parties—the district court did not justifiably exercise that discretion here. Instead, the district court applied an unusual pre- sumption: it said that the party with the burden of proof (here, the government) should have more time for closing argument. We agree with Hernandez that the district court abused its discretion by applying this unusual presumption of unequal treatment. None- theless, we cannot say that this error was prejudicial. The differ- ence in argument time was small, and the evidence of Hernandez’s fraud was overwhelming. Accordingly, we are convinced that the court’s error was harmless. Hernandez’s other arguments are similarly unavailing. She argues that the district court (1) committed plain error when it mis- read a jury instruction, (2) should have struck a juror for cause even though the juror never served, (3) was too involved in advising the parties how to introduce Hernandez’s inculpatory statement, and (4) erred in applying the Sentencing Guidelines. These arguments 24-10047 Opinion of the Court 3

are inconsistent with our precedents or otherwise fail to sufficiently challenge her conviction. Accordingly, we affirm the district court. I.

A.

The evidence at trial establishes that Hernandez began de- frauding Medicare in 2018. Her fraud began when medical recruiter Barton Associates offered to pay her in exchange for signing pre- scriptions from telemarketers. The first prescriptions that she signed were for orthotic braces, also referred to as durable medical equipment, for body parts like the back, knee, or shoulder. At first, the fraud worked like this: the telemarketers cold- called Medicare beneficiaries and offered to send them free or low- cost medical equipment. If the beneficiary agreed, the call center prefilled the prescription forms and sent them to Hernandez for signature. The call centers then sold the prescriptions to medical equipment providers for hundreds of dollars per beneficiary. The medical equipment providers then billed Medicare. And Barton As- sociates would pay Hernandez a kickback for the prescriptions she signed. Hernandez signed many of these prescriptions within sec- onds, and she signed thousands each month. She often prescribed multiple braces for each beneficiary. And she did so without ever performing a physical exam on the patients to determine the med- ical necessity of the prescription. Indeed, many of the patient charts 4 Opinion of the Court 24-10047

contained information that appeared to be cut and pasted from other patients or was internally inconsistent. Eventually, the fraud became too big for Hernandez to han- dle on her own. So she recruited a close friend and nurse, Joanna Ledesma—along with family members—to help her sign prescrip- tions. Ledesma was not qualified to sign prescriptions, and Hernan- dez told her not to call beneficiaries but instead to fabricate call logs and make up symptoms. Then Hernandez grew nervous. In Operation Brace Your- self, the government cracked down on a very similar medical equipment marketing scheme. That month, Hernandez’s equip- ment orders declined, and she took steps to cover her tracks by re- porting her National Provider Identifier as stolen to the police, Medicare, and the Office of the Inspector General. But instead of winding down her fraudulent activities, Her- nandez pivoted to prescribing medically unnecessary genetic screenings. This scheme worked in essentially the same way that the medical equipment scheme worked. Telemarketers contacted Medicare beneficiaries and sold them unnecessary testing. The tel- emarketers sent Hernandez the prefilled prescription forms for sig- nature, and they then sold the prescriptions to labs that billed Med- icare. When Hernandez signed these documents, she attested to her personal relationship with the beneficiaries, even though no such personal relationship existed. And after Hernandez filled the prescriptions, the telemarketers paid her. Between 2018 and 2021, 24-10047 Opinion of the Court 5

Hernandez prescribed more genetic tests than any other provider in the United States. Again, Hernandez began to grow nervous. In Operation Double Helix, the government charged multiple defendants in a similar genetic testing scheme. Upon learning of this, Hernandez sent a DOJ press release about the charges to a nurse whom she had recruited. And at around this time, Hernandez’s genetic test orders declined. But still the fraud was not over. As the COVID-19 pandemic swirled, Hernandez found a new way to defraud Medicare: billing for thousands of telemedicine visits that never occurred. She billed for so many telemedicine appointments that, on many days, she claimed more than twenty-four hours’ worth of visits. All in all, Hernandez received over $1.66 million in kick- backs and direct Medicare payments from all her varying forms of fraud. Predictably, Medicare documented hundreds of complaints against Hernandez, sent her record requests that went unfulfilled, and eventually suspended payments to her. She told associates that she was scared, and that the FBI had accused her of lying. And she began deleting texts to cover up her tracks. Then, in November 2021, during an unrelated health care fraud investigation, the FBI, working with the Department of Health and Human Services, the Office of the Inspector General, and the local police, obtained and executed a search warrant on Hernandez’s residence. During this search, law enforcement found 6 Opinion of the Court 24-10047

a written statement in which Hernandez admitted to participating in fraud. B.

A grand jury indicted Hernandez in April 2022. She was in- dicted for one count of conspiracy to commit health care fraud and wire fraud under 18 U.S.C. § 1349, six counts of health care fraud under 18 U.S.C. § 1347, and three counts of false statements relat- ing to health care matters under 18 U.S.C. § 1035. In the months leading up to Hernandez’s trial, a magistrate judge conducted a pretrial motion in limine hearing. As relevant here, the hearing focused on whether the attorney-client privilege barred admission of Hernandez’s written statement, found during the search of her home, confirming her involvement in the fraud.

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