United States v. Golding, No. 15-2555 (8th Cir. 2016)Annotate this Case
Defendant appealed his conviction for defrauding a health-care benefits program, and of making false statements about the delivery or payment for healthcare benefits. The court concluded that the district court did not abuse its discretion by admitting testimony under Federal Rule of Evidence 404(b) regarding a prior investigation about his physician assistant and a prior settlement agreement with his pharmacy. In this case, the district court did not clearly abuse its discretion in ruling that the investigation and settlement were relevant to defendant's intent and knowledge, and were not overly prejudicial. Furthermore, the district court gave a limiting instruction that the evidence could be considered only on the issue of whether defendant acted knowingly and willfully. Finally, the district court did not abuse its discretion in finding that the proposed testimony about other employees and defendant's patient care was irrelevant to the charged offenses. Accordingly, the court affirmed the judgment.