Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

BlueCross BlueShield of Tennessee (BlueCross) is an insurer and fiduciary for an ERISA-governed group health insurance plan. A plan member in New Hampshire sought coverage for fertility treatments, which BlueCross denied as the plan did not cover such treatments. The Commissioner of the New Hampshire Insurance Department initiated an enforcement action against BlueCross, alleging that the denial violated New Hampshire law, which mandates coverage for fertility treatments. BlueCross sought to enjoin the state regulatory action, arguing it conflicted with its fiduciary duties under ERISA.The United States District Court for the Eastern District of Tennessee denied BlueCross's request for relief and granted summary judgment to the Commissioner. The court found that the Commissioner’s enforcement action was against BlueCross in its capacity as an insurer, not as a fiduciary, and thus was permissible under ERISA’s saving clause, which allows state insurance regulations to apply to insurers.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that the Commissioner’s action was indeed against BlueCross as an insurer, aiming to enforce New Hampshire’s insurance laws. The court noted that ERISA’s saving clause permits such state actions and that BlueCross could not use its fiduciary duties under ERISA to evade state insurance regulations. The court also referenced the Supreme Court’s decision in UNUM Life Insurance Co. of America v. Ward, which established that state insurance regulations are not preempted by ERISA when applied to insurers. Thus, the Sixth Circuit concluded that ERISA did not shield BlueCross from the New Hampshire regulatory action. View "BlueCross BlueShield of Tennessee v. Nicolopoulos" on Justia Law

Jeffrey Campbell, the owner and lead doctor at Physicians Primary Care (PPC), and Mark Dyer, a nurse practitioner at PPC, were indicted in 2020 on multiple counts related to overprescribing opioids and engaging in a scheme to seek fraudulent reimbursements from health insurance providers. The indictment included charges of unlawfully distributing controlled substances, conspiracy to unlawfully distribute controlled substances, health-care fraud, conspiracy to commit health-care fraud, and money laundering.The case proceeded to trial in the United States District Court for the Western District of Kentucky. The jury found Campbell guilty on several counts, including conspiracy to unlawfully distribute controlled substances, health-care fraud, conspiracy to commit health-care fraud, and money laundering. Dyer was also found guilty on similar counts. The district court sentenced Campbell to 105 months of imprisonment and Dyer to 60 months, followed by three years of supervised release for both. The district court also ordered restitution payments from both defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case. The defendants challenged the jury instructions, sufficiency of the evidence, and the district court’s evidentiary rulings. The appellate court found that the jury instructions, although not fully compliant with the Supreme Court's decision in Ruan v. United States, were adequate under the court's precedents. The court also found sufficient evidence to support the convictions for conspiracy to unlawfully distribute controlled substances, health-care fraud, and money laundering. The court held that the district court did not abuse its discretion in admitting the testimony of government experts and other evidence.The appellate court affirmed the convictions and sentences, concluding that any potential errors in the district court’s intended-loss calculation for sentencing were harmless, as the sentences imposed were well below the applicable Guidelines range. The court also noted that the defendants failed to properly appeal the restitution order, making it outside the scope of the current appeal. View "United States v. Campbell" on Justia Law

Sardar Ashrafkhan owned and operated a fraudulent medical practice where doctors wrote and billed Medicare for fake prescriptions. These prescriptions were filled at specific pharmacies, which paid Ashrafkhan kickbacks. The scheme resulted in millions of dollars in fraudulent Medicare claims and the illegal sale of opioid-based drugs. Ashrafkhan was indicted in 2013 and tried in 2015, where the government presented evidence that he masterminded the scheme. The jury convicted him of drug conspiracy, health care fraud conspiracy, and money laundering. At sentencing, he received an adjustment for being an organizer or leader of a criminal activity involving five or more participants.The United States District Court for the Eastern District of Michigan sentenced Ashrafkhan to 276 months of imprisonment, varying downward from the guidelines range of 600 months. Ashrafkhan appealed, and the United States Court of Appeals for the Sixth Circuit affirmed his conviction and sentence. After his sentencing, the United States Sentencing Commission promulgated a new guideline, USSG § 4C1.1, which provides a two-point reduction in the offense level for defendants with no criminal history points, known as "zero-point offenders." Ashrafkhan moved for a sentence reduction under this new guideline, but the district court denied his motion, reasoning that his aggravating role adjustment rendered him ineligible for the reduction.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that to be eligible for the zero-point offender reduction under USSG § 4C1.1, a defendant must not have received an aggravating role adjustment and must not have engaged in a continuing criminal enterprise. Since Ashrafkhan received an aggravating role adjustment, he was ineligible for the reduction, regardless of whether he engaged in a continuing criminal enterprise. The court's interpretation was based on the plain text and context of the guideline, as well as precedent from similar cases. View "United States v. Ashrafkhan" on Justia Law

Nashaun Drake pleaded guilty to several drug offenses after police found significant quantities of fentanyl, cocaine, methamphetamine, and drug trafficking tools in his apartment. He was charged with five counts of possessing illegal drugs with intent to distribute. At sentencing, the district court classified Drake as a "career offender" based on a prior marijuana conviction, resulting in a 200-month prison sentence.The United States District Court for the Northern District of Ohio determined that Drake's prior marijuana conviction qualified as a predicate offense for the career-offender enhancement under the Sentencing Guidelines. This classification led to a sentencing range of 188 to 235 months, and the court imposed a 200-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Drake argued that his prior marijuana conviction should not have triggered the career-offender enhancement and that his sentence was unreasonable. The court held that binding precedent required the use of a time-of-conviction approach to determine whether a prior offense qualifies as a "controlled substance offense" under the Sentencing Guidelines. Since hemp was included in the drug schedules at the time of Drake's 2016 conviction, his marijuana offense qualified as a controlled substance offense. The court also found that the district court did not abuse its discretion in imposing a 200-month sentence, considering Drake's extensive criminal history and the need for deterrence and public protection.The Sixth Circuit affirmed the district court's decision, upholding both the career-offender enhancement and the 200-month sentence. View "United States v. Drake" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

Annette McEachin, a human resources manager, was seriously injured in a car accident in 2017 and subsequently filed a disability claim with Reliance Standard Life Insurance Company. Reliance approved her for long-term disability benefits, which were later extended after another car accident worsened her condition. McEachin underwent multiple surgeries and treatments for her physical injuries and also received treatment for mental health issues, including depression and anxiety, exacerbated by her son's suicide in 2019. Reliance paid her benefits for nearly four years but stopped payments in April 2021, concluding that her physical health had improved sufficiently for her to return to work.The United States District Court for the Eastern District of Michigan found that McEachin no longer had a physical disability as of April 2021 but ruled that her mental health disabilities entitled her to two more years of benefits. Both parties appealed the decision. Reliance argued that the district court misinterpreted the insurance policy, while McEachin contended that her physical disabilities persisted beyond April 2021.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that McEachin's physical disabilities alone justified her disability benefits until April 2021, meaning the 24-month mental health limitation did not apply until then. The court affirmed the district court's finding that McEachin's physical disabilities no longer rendered her totally disabled as of April 2021. However, the court vacated the district court's decision regarding the mental health benefits and remanded the case to consider whether McEachin's post-April 2021 medical evidence could toll the 24-month mental health limitation period, potentially extending her eligibility for benefits beyond April 2023. View "McEachin v. Reliance Standard Life Ins. Co." on Justia Law

Chadrick Perry was indicted for being a felon in possession of a firearm and ammunition. After pleading not guilty, he was detained pending trial. Concerns about his competency led to evaluations by two forensic psychologists, who reached different conclusions. The district court committed Perry to the custody of the Attorney General for competency restoration. Perry experienced significant delays in being transported to a federal facility for treatment. Eventually, he was deemed competent, pleaded guilty to being a felon in possession of ammunition, and was sentenced to 57 months in prison.The United States District Court for the Western District of Michigan denied Perry's motion to dismiss the indictment based on alleged violations of the Speedy Trial Act. Perry argued that the 152-day delay between his designation for treatment and his arrival at the facility should count against the Act's 70-day clock. The district court ruled that the entire period from when Perry was deemed incompetent until his competency was restored was excludable under the Act.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the entire period of delay resulting from Perry's mental incompetence was excludable under 18 U.S.C. § 3161(h)(4). This exclusion applied even during the transportation delay, thus not violating the Speedy Trial Act. Additionally, the court upheld Perry's sentence, determining that his prior conviction for aggravated domestic violence qualified as a "crime of violence" under U.S.S.G. § 4B1.2(a), justifying the increased Guidelines range. The court affirmed both the conviction and the sentence. View "United States v. Perry" on Justia Law

In 2021, the U.S. Department of Health and Human Services (HHS) issued a rule requiring Title X grant recipients to provide neutral, nondirective counseling and referrals for abortions upon patient request. Tennessee, a long-time Title X recipient, recently enacted laws criminalizing most abortions. Consequently, Tennessee limited its counseling and referrals to options legal within the state, leading HHS to discontinue its Title X grant, citing non-compliance with federal regulations. Tennessee sued to challenge this decision and sought a preliminary injunction to prevent the grant's termination.The United States District Court for the Eastern District of Tennessee denied Tennessee's request for a preliminary injunction. The court concluded that Tennessee was unlikely to succeed on the merits of its claim and that the balance of the preliminary injunction factors favored HHS. The court found that Tennessee did not demonstrate a strong likelihood of success on its claims under the Spending Clause or the Administrative Procedure Act (APA).The United States Court of Appeals for the Sixth Circuit reviewed the district court's decision and affirmed the denial of the preliminary injunction. The appellate court held that HHS's 2021 Rule was a permissible construction of Title X and that Tennessee had voluntarily and knowingly accepted the grant's terms, including the counseling and referral requirements. The court also found that HHS's actions did not violate the Spending Clause or the APA. The court concluded that Tennessee failed to show irreparable harm and that the public interest favored the correct application of Title X regulations. Therefore, the district court's decision to deny the preliminary injunction was upheld. View "Tennessee v. Becerra" on Justia Law

The case involves Joseph Betro, Mohammed Zahoor, Tariq Omar, and Spilios Pappas, who conspired to defraud Medicare by administering medically unnecessary back injections and bribing patients with opioid prescriptions. They fraudulently billed these injections as “facet injections” to receive higher reimbursements. Additionally, they ordered unnecessary urine drug tests and referred patients to ancillary services in exchange for kickbacks. Despite patient complaints about the ineffectiveness and pain of the injections, the defendants continued their fraudulent practices.A jury in the United States District Court for the Eastern District of Michigan convicted the defendants of conspiracy to commit healthcare fraud and wire fraud under 18 U.S.C. § 1349 and healthcare fraud under 18 U.S.C. § 1347. The defendants filed motions for a new trial, which the district court denied. They then appealed their convictions and sentences, raising various challenges related to the prosecution, evidence admission, jury instructions, and sentencing calculations.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgments. The court found sufficient evidence to support the jury’s findings that the defendants knowingly participated in the fraudulent scheme. The court also held that the district court did not abuse its discretion in denying the motions for a new trial, admitting evidence, or instructing the jury. The sentences imposed were deemed procedurally and substantively reasonable, with the court noting that the district court had appropriately calculated the loss amounts and applied relevant sentencing enhancements. View "United States v. Betro" on Justia Law

The case involves the United States of America, et al. ex rel. Michael Angelo and MSP WB, LLC (Relators-Appellants) against Allstate Insurance Company, et al. (Defendants-Appellees). The relators alleged that Allstate Insurance violated the False Claims Act by avoiding its obligations under the Medicare Secondary Payer Act. They claimed that Allstate failed to report or inaccurately reported to the Centers for Medicare & Medicaid Services (CMS) information regarding its beneficiaries, which led to Allstate failing to reimburse Medicare for auto-accident-related medical costs incurred by beneficiaries insured by Allstate.The United States District Court for the Eastern District of Michigan dismissed the case with prejudice, deeming the relators' second amended complaint deficient in numerous respects. The relators then moved for reconsideration, which the district court denied. They also filed a motion to amend or correct under Rule 59(e), asking the district court to amend its judgment to dismiss the case without prejudice to allow them to file another amended complaint. The district court denied the motion on all grounds.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the relators failed to state a claim for a violation of the False Claims Act. The court noted that the relators did not provide sufficient facts demonstrating that Allstate had an "established duty" to pay money or property owed to the government. The court also found that the relators did not demonstrate Allstate's understanding that its conduct violated its obligations under federal law. Furthermore, the court found that the relators' claim for conspiracy also failed as they did not provide any specific details regarding the alleged plan or an agreement to execute the plan. The court also affirmed the district court's decision to deny the relators leave to amend their complaint again. View "United States ex rel. Angelo v. Allstate Insurance Co." on Justia Law