United States v. Mahmoud Rahim

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 7, 2019
Docket18-1172
StatusUnpublished

This text of United States v. Mahmoud Rahim (United States v. Mahmoud Rahim) 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. Mahmoud Rahim, (6th Cir. 2019).

Opinion

NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 19a0244n.06

Case No. 18-1172

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 07, 2019 UNITED STATES OF AMERICA, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF MAHMOUD RAHIM, ) MICHIGAN ) Defendant-Appellant. ) )

BEFORE: SUHRHEINRICH, THAPAR, and LARSEN, Circuit Judges.

THAPAR, Circuit Judge. Doctor Mahmoud Rahim made money by referring his patients

to other doctors in exchange for kickbacks. As a result of this practice, a jury convicted him of

healthcare fraud. He appeals his conviction and sentence. We affirm.

I.

Rahim teamed up with other physicians, including Rizwan Qadir, to accept kickbacks in

exchange for patient referrals. Rahim would refer patients to Qadir, a neurologist, who in turn

paid Rahim (1) a flat fee per month and (2) additional referral fees each time Rahim referred a

patient for an EMG (a muscle test) or physical therapy. Rahim referred nearly three quarters of

his patients to Qadir for an EMG, physical therapy, or both. An EMG is an invasive and sometimes

painful test that involves sticking needles into a patient’s muscles. And Rahim referred patients Case No. 18-1172, United States v. Rahim

for this test even when Qadir believed the test was unnecessary or the patient complained about

not wanting another EMG. But at least the EMG was a real test performed by a real doctor. That

much can hardly be said about the physical therapy. Rahim referred his patients to unlicensed

“physical therapists” who prescribed the exact same plan of care for every patient, regardless of

the patient’s condition.

Many of Rahim’s patients were Medicare beneficiaries, and it is a crime to submit

fraudulent bills to Medicare or to give or receive kickbacks in connection with treating Medicare

patients. 18 U.S.C. §§ 371, 1347; 42 U.S.C. § 1320a-7b(b)(1). So Rahim tried to make his fraud

fly under the government’s radar. To hide the kickbacks, Rahim attempted to make it look like

Qadir was simply paying him rent for office space. Qadir would write Rahim two kickback checks

each month. One was always for the same amount and had “rent” or “lease” written in the memo

line. The other was for any extra referral fees and generally went to another company, including

a shell company that someone else, such as Rahim’s son or an employee, technically “owned” but

that Rahim controlled. The only time they did not use this method of payment was when Rahim

went through bankruptcy; during that time, Qadir paid Rahim in cash to avoid bankruptcy-court

scrutiny.

Despite Rahim’s best efforts to conceal this fraud, the government eventually caught on.

It charged Rahim with (1) conspiracy to commit healthcare fraud and wire fraud, (2) wire fraud,

(3) conspiracy to pay and receive healthcare kickbacks, and (4) receipt of kickbacks in connection

with a federal healthcare program (Medicare). A jury convicted Rahim on all charges, and he was

sentenced to seventy-two months in prison. On appeal, Rahim claims the district court made

several errors—both during the trial and at sentencing.

-2- Case No. 18-1172, United States v. Rahim

II.

A.

At trial, Rahim claimed that Qadir’s monthly checks were rent payments, not kickbacks.

But the government introduced evidence from Rahim’s bankruptcy proceedings to show

otherwise. First, the government used the bankruptcy evidence to rebut Rahim’s claim that Qadir

was a tenant. Second, the government used the bankruptcy evidence to explain a gap in time where

Rahim did not receive any rent checks from Qadir.

Rebuttal. During his bankruptcy proceedings, Rahim listed his tenants on multiple

occasions, but he never included Qadir. The government argued that this proved that Qadir was

not in fact a tenant, and therefore, his payments to Rahim were not for rent. This evidence was

introduced in two forms: Rahim’s own testimony during the bankruptcy proceedings and a

bankruptcy examiner’s report that summarized Rahim’s statements.

Missing checks. The government also needed to explain to the jury why Qadir’s rent checks

ceased for two years. Again, the answer was the bankruptcy proceedings. The government’s

theory was that Rahim had Qadir pay him in cash rather than checks during this period because

the bankruptcy court was scrutinizing Rahim’s finances.

Rahim objected to the introduction of the bankruptcy evidence, arguing that it (1) was

hearsay, (2) was a prior act offered to prove character, and (3) presented a risk of unfair prejudice,

wasting time, or confusing the issues. See Fed. R. Evid. 802, 404(b), 403. The court overruled

the objections and admitted the evidence.

On appeal, Rahim adds a new argument: the admission of the evidence violated the

Confrontation Clause. We review his three renewed challenges for abuse of discretion, but we

-3- Case No. 18-1172, United States v. Rahim

review his new Confrontation Clause challenge for plain error. United States v. Churn, 800 F.3d

768, 774–75 (6th Cir. 2015); United States v. Demjanjuk, 367 F.3d 623, 629 (6th Cir. 2004).

Hearsay. First, Rahim argues that the bankruptcy examiner’s report is inadmissible

hearsay. Hearsay is (1) an out-of-court statement (2) offered for the truth of the matter asserted in

that statement. Fed. R. Evid. 801(c). But although certain statements look like hearsay, walk like

hearsay, and talk like hearsay, they are “not hearsay” under the Federal Rules of Evidence. See

Fed. R. Evid. 801(d). One example is when a party makes a statement outside of court and the

other side uses that statement against him at trial; that is “not hearsay.” Fed. R. Evid. 801(d)(2)(A).

So when the government offered Rahim’s own statements from the bankruptcy proceedings, they

were “not hearsay.” United States v. Lay, 612 F.3d 440, 448 (6th Cir. 2010). Rahim concedes as

much. And this concession is fatal to his objection to the bankruptcy examiner’s report. Why?

Because while the bankruptcy examiner’s report is an out-of-court statement that should not have

been admitted, any error in admitting it was harmless. The report merely summarized what the

jury had already heard in the form of Rahim’s own statements—that Qadir was not a tenant. See

United States v. Davis, 577 F.3d 660, 670 (6th Cir. 2009) (explaining that an error in admitting a

hearsay statement is subject to harmless error analysis).

Plus, there was additional overwhelming evidence of Rahim’s guilt. The jury saw videos

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

Related

Stinson v. United States
508 U.S. 36 (Supreme Court, 1993)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
United States v. Lay
612 F.3d 440 (Sixth Circuit, 2010)
United States v. Ham
628 F.3d 801 (Sixth Circuit, 2011)
United States v. Boyd
640 F.3d 657 (Sixth Circuit, 2011)
United States v. John Demjanjuk
367 F.3d 623 (Sixth Circuit, 2004)
United States v. Larry Swafford
385 F.3d 1026 (Sixth Circuit, 2004)
United States v. Luis Lopez-Medina
461 F.3d 724 (Sixth Circuit, 2006)
Williams v. Illinois
132 S. Ct. 2221 (Supreme Court, 2012)
United States v. Marcus Freeman
730 F.3d 590 (Sixth Circuit, 2013)
United States v. Davis
577 F.3d 660 (Sixth Circuit, 2009)
United States v. White
492 F.3d 380 (Sixth Circuit, 2007)
United States v. Warman
578 F.3d 320 (Sixth Circuit, 2009)
United States v. Malek al-Maliki
787 F.3d 784 (Sixth Circuit, 2015)
United States v. Kwame Kilpatrick
798 F.3d 365 (Sixth Circuit, 2015)
United States v. Keith Churn
800 F.3d 768 (Sixth Circuit, 2015)
United States v. Michael Thoran
819 F.3d 298 (Sixth Circuit, 2016)
United States v. Iraephraim Underwood
859 F.3d 386 (Sixth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Mahmoud Rahim, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-mahmoud-rahim-ca6-2019.