United States v. Joseph

108 F.4th 1273
CourtCourt of Appeals for the Tenth Circuit
DecidedJuly 29, 2024
Docket23-1192
StatusPublished
Cited by9 cases

This text of 108 F.4th 1273 (United States v. Joseph) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Joseph, 108 F.4th 1273 (10th Cir. 2024).

Opinion

Appellate Case: 23-1192 Document: 010111086158 Date Filed: 07/29/2024 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS July 29, 2024 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 23-1192

FRANCIS F. JOSEPH,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the District of Colorado (D.C. No. 1:21-CR-00083-RM-1) _________________________________

Elizabeth A. Franklin-Best, Elizabeth Franklin-Best, P.C., Columbia, South Carolina, for Defendant – Appellant.

John J. Liolos, Trial Attorney (Nicole M. Argentieri, Acting Assistant Attorney General; Lisa H. Miller, Deputy Assistant Attorney General, with him on the brief), Fraud Section, Criminal Division, U.S. Department of Justice, Washington, D.C., for Plaintiff – Appellee. _________________________________

Before McHUGH, MURPHY, and CARSON, Circuit Judges. _________________________________

MURPHY, Circuit Judge. _________________________________

I. Introduction

Dr. Francis Joseph was the founder of Springs Medical Associates (“Springs

Medical”), a medical practice based in Colorado Springs, Colorado. Following an ill- Appellate Case: 23-1192 Document: 010111086158 Date Filed: 07/29/2024 Page: 2

fated corporate governance agreement which installed a new Chief Operating Officer

(“COO”), Joseph concocted a scheme for the alleged purpose of regaining control of

the practice. Between March and June 2020, he submitted several false and

unauthorized applications to federal COVID-19 relief programs on Springs Medical’s

behalf. As a result, Joseph received over $250,000 in federal aid, which he disguised

from Springs Medical leadership and ultimately misspent for personal gain.

In 2023, a jury convicted Joseph of two fraud-based counts. On appeal, he

argues insufficient evidence existed to demonstrate he possessed the requisite intent

to commit the offenses. He also presents several challenges to his trial and sentencing

proceedings, including that the district court improperly (a) limited his cross-

examination and introduction of evidence; (b) admitted expert testimony as lay

testimony; (c) allowed the government to introduce Fed. R. Evid. 404(b)(1)

propensity evidence; (d) declined to provide clarifying jury instructions; and (e)

miscalculated the economic loss under the sentencing guidelines occasioned by his

offenses. This court concludes the record is replete with direct and circumstantial

evidence that Joseph intended to commit fraud through his relief program

applications. Further, except for the district court’s admission of expert testimony in

the guise of lay testimony, which was harmless, the district court neither erred in

sentencing nor abused its discretion in conducting Joseph’s trial. Thus, exercising

jurisdiction pursuant to 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a), this court affirms

the district court’s judgment.

2 Appellate Case: 23-1192 Document: 010111086158 Date Filed: 07/29/2024 Page: 3

II. Background

a. Federal Relief Programs

Joseph completed unauthorized applications for two federally funded relief

programs: the Accelerated and Advance Payment Program (“AAP”); and the

Paycheck Protection Program (“PPP”). In light of the strain caused by the COVID-19

pandemic on national healthcare, the Centers for Medicare and Medicaid Services

(“CMS”) expanded the existing AAP to cover a broader range of Medicare providers.

The program supplied funds to providers who experienced disruptions in Medicare

claim submissions and processing. As long as applicants met basic criteria, AAP

allowed providers to request a loan of up to 100% of Medicare payments for a three-

month period. The loans permitted providers to receive full payment for claims until

the date of recoupment, which began one year following the issuance of the loan.

During this collection period, Medicare automatically offset amounts owed for new

claims to repay the advanced funds.

PPP was authorized by the Coronavirus Aid, Relief, and Economic Security

(“CARES”) Act in March 2020 to help businesses weather the unpredictable

economic conditions caused by the pandemic. The loans were facilitated by the Small

Business Administration (“SBA”) and were forgivable if used for the limited

purposes of payroll retention and paying mortgage interest, rent, or utilities. To

obtain a PPP loan, a qualifying business had to submit a signed application from an

authorized representative of the company. Candidates were further required to certify

their acknowledgment of the program rules and provide payroll details. Both PPP and

3 Appellate Case: 23-1192 Document: 010111086158 Date Filed: 07/29/2024 Page: 4

AAP loans were processed by third-party lenders, which coordinated with

government entities to ensure applicants were properly approved and received the

correct amount of relief.

b. Factual & Procedural History

Joseph was the founder and managing physician of Springs Medical. He

managed and controlled the practice until January 29, 2020, when Springs Medical

adopted a document entitled “Joint Action by Written Consent of the Directors and

Shareholders of [Springs Medical]” (the “Joint Action Document”). The Joint Action

Document appointed Eric Papalini as Springs Medical’s COO and bestowed upon

him the authority and discretion to “make all actions necessary or desirable related to

the operation of [Springs Medical].” As particularly relevant here, Papalini’s

authority included, “without limitation, the authority to hire and fire employees,

manage [Springs Medical’s] banking accounts, make all decisions regarding [Springs

Medical’s] finances, borrow money in the name of [Springs Medical], make any

contracts, enter into any transactions and make and obtain any commitments on

behalf of [Springs Medical] deemed necessary or appropriate in his sole direction.”

After the Joint Action Document was executed, Joseph retained his shareholder

status, but his day-to-day role was reduced to serving as a physician-employee.

On the same day that Congress signed the CARES Act into law, March 27,

2020, Joseph opened an unauthorized bank account in Springs Medical’s name

(hereafter, the “Unauthorized Bank Account”), making himself the sole signatory.

His actions violated the terms of the Joint Action Document, which vested control of

4 Appellate Case: 23-1192 Document: 010111086158 Date Filed: 07/29/2024 Page: 5

practice finances in Papalini. Joseph, however, claimed he opened the Unauthorized

Bank Account because of a dispute with Papalini over his leadership and business

decisions. He took offense to Papalini’s behavior and purportedly considered it wise

to disguise his financial dealings in preparation to oust Papalini from practice

operations.

On or about March 29, 2020, Joseph applied for AAP relief on behalf of

Springs Medical without authorization from Papalini. He requested the maximum

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

Related

United States v. Briscoe
Tenth Circuit, 2026
United States v. Eckstein
Tenth Circuit, 2026
United States v. Cunningham
Tenth Circuit, 2025
United States v. Sandoval
Tenth Circuit, 2025
United States v. Hardy
Tenth Circuit, 2025
United States v. Sjodin
139 F.4th 1188 (Tenth Circuit, 2025)
United States v. Berris
Tenth Circuit, 2025
United States v. Thomas
Tenth Circuit, 2025
United States v. Bruce
127 F.4th 246 (Tenth Circuit, 2025)
United States v. Molyneux
Tenth Circuit, 2024

Cite This Page — Counsel Stack

Bluebook (online)
108 F.4th 1273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joseph-ca10-2024.