United States v. Isaac Knight

CourtCourt of Appeals for the Sixth Circuit
DecidedNovember 28, 2018
Docket17-3604
StatusUnpublished

This text of United States v. Isaac Knight (United States v. Isaac Knight) 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. Isaac Knight, (6th Cir. 2018).

Opinion

NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 18a0595n.06

Nos. 17-3604/3612

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Nov 28, 2018 UNITED STATES OF AMERICA, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) v. UNITED STATES DISTRICT ) COURT FOR THE ) ISAAC R. KNIGHT and DELORES L. KNIGHT, NORTHERN DISTRICT OF ) OHIO Defendants-Appellants. )

Before: COLE, Chief Judge; GRIFFIN and KETHLEDGE, Circuit Judges.

KETHLEDGE, Circuit Judge. Delores and Isaac Knight, mother and son, were convicted

of healthcare fraud and conspiracy to commit the same. They each challenge the sufficiency of

the evidence supporting their convictions. Delores also challenges the district court’s denial of her

motion to sever her trial from Isaac’s, and Isaac challenges his sentence. We affirm both

defendants’ convictions, but vacate Isaac’s sentence because the district court made a mistake of

fact when it applied a Guidelines enhancement for obstruction of justice.

I.

For about ten years, Delores Knight headed Just Like Familee (Familee), a business that

provided home-healthcare services in Ohio. Delores’s daughter, Theresa Adams, co-owned the

business and directed sales and marketing. Delores’s son, Isaac Knight, managed a branch office

in Mentor, Ohio. Nos. 17-3604/3612, United States v. Knight

From 2007 to 2014, Familee engaged in healthcare fraud. Among other things, the

company falsely certified compliance with Medicare, Medicaid, and Veterans Affairs rules, billed

multiple agencies for the same service, and billed for services not provided (including for patients

who were already deceased). Eventually, the government’s auditors caught on. Various reviews

showed that 70 to 100 percent of Familee’s claims were improper—if not fraudulent. Medicare,

Medicaid, and Veterans Affairs then barred the company from billing for any more services. In

response, Delores, Theresa, and Isaac started a new company, Elegance Home Health, and Isaac

applied for accreditation to begin billing Medicare again.

Soon thereafter, a grand jury indicted Delores and Isaac (among others) for healthcare

fraud, conspiracy to commit healthcare fraud, and money laundering, in violation of 18 U.S.C. §§

1347, 1349, 1957. The grand jury also indicted Isaac for making a false statement on Elegance’s

application for Medicare accreditation, in violation of 18 U.S.C. § 1035, on the theory that Isaac

falsely marked the “No” checkbox in response to the question whether Medicare had ever taken

an adverse action against the applicant. Before trial, Delores moved to sever her trial from Isaac’s.

The district court denied the motion.

The district court thereafter conducted an eleven-day joint trial. The jury convicted Delores

on all counts, and convicted Isaac on all counts except the one that he had made a false statement

on Elegance’s application. The district court sentenced Delores to 120 months’ imprisonment and

Isaac to 87 months, and also ordered both defendants, jointly and severally, to pay restitution in

the amount of $8,168,107.24. These appeals followed.

-2- Nos. 17-3604/3612, United States v. Knight

II.

A.

Delores and Isaac challenge the sufficiency of the evidence supporting their convictions

for healthcare fraud and conspiracy to commit the same. When reviewing a guilty verdict, “the

relevant question is whether, after viewing the evidence in the light most favorable to the

prosecution, any rational trier of fact could have found the essential elements of the crime beyond

a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319 (1979) (emphasis in original).

No one disputes that the government proved fraud. Indeed, Delores admits that “[t]here is

no question” that Familee “engaged in numerous criminal activities.” She and Isaac argue only

that the prosecution lacked sufficient evidence that they personally were involved in the frauds.

The government had ample evidence of Delores’s involvement. Familee’s nursing director

testified that Delores had asked her to make false statements on medical forms. The company’s

billing clerk testified that Delores had told her to lie on forms, and that Delores—who supervised

the medical records department—had known that the billed services were improperly documented.

A vendor who sold billing software to Familee testified that Delores had asked how to disable the

software’s double-billing safeguards. Several Familee employees testified that nothing “happened

at Just Like Familee” that Delores “didn’t oversee or have a role in.” This evidence allowed the

jury reasonably to conclude that Delores had committed fraud and conspired to do so. That

conclusion likewise disposes of Delores’s challenge to the evidence supporting her money-

laundering conviction, because (as she admits) that argument is derivative of her challenge to her

fraud convictions.

The government’s case against Isaac was similar. The company’s nursing director testified

that Isaac had told her to certify phony visits to patients, and that Isaac had been copied on other

-3- Nos. 17-3604/3612, United States v. Knight

emails requesting fraudulent signatures and forged notes. A receptionist also testified that Isaac

had told her to ask various nurses fraudulently to sign forms, and that when those nurses had

refused, Isaac had told her to fax the unsigned forms to the nursing director for signature.

Documents also showed that Isaac had been involved in founding Elegance Home Health shortly

after Familee was barred from billing the agencies—which strengthened the inference that he was

in on the scheme. This evidence was enough for the jury to find that Isaac committed healthcare

fraud and conspired to do the same.

Isaac argues that the jury’s finding that he committed healthcare fraud conflicts with its

acquittal of him on the charge that he made false statements in Elegance’s application. But an

inconsistent verdict does not by itself warrant a retrial. See United States v. Lawrence, 555 F.3d

254, 262 (6th Cir. 2009). And in any event the jury’s findings were not inconsistent: if Isaac did

not lie on Elegance’s application, he still could have been a participant in Familee’s fraud. As

indeed the evidence showed he was. His argument is meritless.

B.

Delores argues that the district court should have granted her motion to sever her trial from

Isaac’s because, she says, evidence of Isaac’s fraud unduly prejudiced her case. We review the

district court’s denial for an abuse of discretion. United States v. Cody, 498 F.3d 582, 586 (6th

Cir. 2007). As relevant here, Delores must make a “strong showing of prejudice” and show that

joinder prevented the jury from “making a reliable judgment about guilt or innocence.” United

States v. Hang Le-Thy Tran, 433 F.3d 472, 478 (6th Cir. 2006).

The joinder had no such effect here. Co-conspirators are routinely tried jointly, and

Delores does not explain why this joinder was prejudicial to her. Moreover, the district court

properly instructed the jury to consider separately the evidence regarding each count and each

-4- Nos.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
United States v. George M. Parrott
148 F.3d 629 (Sixth Circuit, 1998)
United States v. Allen Lawrence, Jr.
308 F.3d 623 (Sixth Circuit, 2002)
United States v. Donald Lynn Baggett
342 F.3d 536 (Sixth Circuit, 2003)
United States v. Hang Le-Thy Tran
433 F.3d 472 (Sixth Circuit, 2006)
United States v. Sherry Washington
715 F.3d 975 (Sixth Circuit, 2013)
United States v. Lawrence
555 F.3d 254 (Sixth Circuit, 2009)
United States v. Cody
498 F.3d 582 (Sixth Circuit, 2007)
United States v. Vishnu Meda
812 F.3d 502 (Sixth Circuit, 2015)

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