United States v. Chalker, No. 18-15102 (11th Cir. 2020)
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The Eleventh Circuit affirmed defendant's conviction and sentence for healthcare fraud and conspiracy to commit healthcare fraud. The court held that sufficient evidence supported defendant's convictions, and that the indictment was plainly sufficient. The court rejected defendant's two evidentiary claims, holding that the district court did not err in permitting an FBI forensic accountant to testify as a lay witness or in allowing a government witness to testify as an expert. The court also held that the district court did not abuse its discretion in denying
defendant's motions for continuance; there was no cumulative error requiring reversal; and the district court did not clearly err in calculating the loss amount and thus the guidelines range.
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