Parole Violation Puts Convicted Insurance Fraudster Back in Jail
Post 4991
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Facts
In Commonwealth Of Pennsylvania v. Kalani Watts, Nos. 2399 EDA 2023, 895 EDA 2024, No. J-S37026-24, Superior Court of Pennsylvania (January 27, 2025) Watts entered a negotiated guilty plea to one count each of obtaining possession of a controlled substance by misrepresentation, fraud, forgery or subterfuge, and insurance fraud. On July 21, 2014, in accordance with the plea agreement, the trial court imposed an aggregate sentence of 6 to 12 years in prison.
Watts also pled guilty to one count of receiving stolen property. On September 3, 2014, the trial court sentenced Appellant to 16 to 36 months in prison, to run concurrently with Appellant’s sentence in the drug and insurance fraud case.
Watts alleged he was paroled on 6-20-19, and moved thereafter to the State of Georgia. Three years later, Watts was arrested on misdemeanors and returned back to Pennsylvania on a parole violation. Upon being seen by the Pennsylvania Board of Probation and Parole (Parole Board), Watts was informed that his maximum sentence was moved from 7-12-2026 to 4-29-29.
The Appeal
In this consolidated appeal, Kalani Watts (Appellant) appeals, pro se, from the orders dismissing as untimely his first petitions filed under the Post Conviction Relief Act (PCRA), 42 Pa.C.S.A. §§ 9541-9546.
Post Conviction Relief
Appellant filed identical, pro se PCRA petitions at two dockets. Appellant filled out portions of a pre-printed PCRA petition form and also incorporated an attached “Petition for Enforcement of Negotiated Plea Agreement” (Attachment).
The PCRA court further observed that Appellant’s petitions appeared to challenge the Parole Board’s decision to revoke his parole and pull his street time. In the alternative, the PCRA court determined that the Parole Board’s decision did not constitute a violation of Appellant’s plea agreement.
Analysis
Pro se litigants must comply with the procedural rules set forth in the Pennsylvania Rules of Court.
Preliminarily, although the Court was willing to construe liberally materials filed by a pro se litigant, a pro se appellant enjoys no special benefit. To the contrary, any person choosing to represent himself in a legal proceeding must, to a reasonable extent, assume that his lack of expertise and legal training will be his undoing.
Here, though Appellant cites various provisions of the federal and state constitutions, he fails to identify any decision of the United States Supreme Court or Pennsylvania Supreme Court recognizing a new constitutional right.
As Appellant has waived each of his issues raised on appeal, the Court of Appeals affirmed the PCRA court’s orders dismissing his petitions.
ZALMA OPINION
People who engage in criminal conduct, especially when that conduct is insurance fraud, are not members of MENSA. Mr. Watts was a regular, albeit inept, criminal. He was lucky enough to be paroled only to be put back in jail for breaching the conditions of his parole by committing some misdemeanors. He then tried to change his sentence by applying as his own attorney for post conviction relief. That also failed because the bases he claimed were not established.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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Happy Law Day
ZIFL – Volume 30, Issue 9 – May 1, 2026
Read the full article at https://www.linkedin.com/pulse/zalmas-insurance-fraud-letter-may-1-2026-barry-zalma-esq-cfe-2tywc, see the video at at and at https://zalma.com/blog plus more than 5300 posts.
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
ZIFL – Volume 30, Issue 9 – May 1, 2026
Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year and is written by Barry Zalma.
DOJ Creates National Fraud Enforcement Division
Will the Feds Take on Insurance Fraud? Possibly as Part of a National Anti-Fraud Effort
On April 7, 2026, the Acting Attorney General, Todd Blanche, issued a memorandum establishing the Department of Justice National Fraud Enforcement Division (NFED). The memo describes an ambitious, but perhaps redundant, vision for this ...
When Abalone Died As a Result of Multiple Causes The Efficient Proximate Cause Requires Payment
Post number 5345
Read the full article at https://www.linkedin.com/pulse/efficient-proximate-cause-doctrine-saves-claim-barry-zalma-esq-cfe-yndlc, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.
In American Abalone Farms, LLC v. Star Insurance Company et al., H052643, California Court of Appeals, Sixth District (April 27, 2026) the Court of Appeals dealt with an insurance coverage issue that required application of the efficient proximate cause doctrine.
FACTS
American Abalone Farms, LLC ("American Abalone" ) operates an aquaculture farm in Santa Cruz County, California, raising abalone in tanks. In August 2020, the CZU Lightning Complex Fires led to a prolonged power outage and road closures near the farm. As a result, the farm’s water pumps failed, causing the death of most of the ...
Breach of a Specific Condition Precedent Is a Complete Defense
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In United Services Automobile Association and State Farm Mutual Automobile Insurance Company v. Anthony Wenzell, 2026 CO 25 (Colo. Apr. 27, 2026) Anthony Wenzell was rear-ended in a car accident. He had a significant prior 2014 accident that required back surgery.
Wenzell claimed underinsured-motorist (UIM) benefits under three policies: (1) the tortfeasor’s liability policy, (2) his own primary UIM policy with State Farm, and (3) an excess UIM policy issued by USAA (under his brother’s policy, which contained an “other insurance” clause making USAA’s coverage excess over any collectible insurance).
After receiving the claims, both USAA and State Farm repeatedly requested that Wenzell execute comprehensive medical-release authorizations so they could obtain his full medical records and ...
It is Fraud to Make the Same Claim Twice
Read the full article at https://www.linkedin.com/pulse/fraud-make-same-claim-twice-barry-zalma-esq-cfe-c4g8c and at https://zalma.com/blog.
Chutzpah: After Being Paid for a New Roof Insured Makes Second Claim For Same Damages
Post number 5347
No One is Entitled to be Paid for the Same Loss Twice
In Mohammed Ali Khalili v. State Farm Lloyds, No. 14-25-00611-CV, Court of Appeals of Texas (April 30, 2026) Khalili maintained a State Farm Lloyds homeowners insurance policy for decades. In 2008 he filed a roof-damage claim; State Farm paid him to replace the entire roof (shingles and gutters). Khalili never replaced the roof and repeated his claim.
BACKGROUND
In 2021 he filed a second roof claim. State Farm’s inspectors found the roof “very old” with extensive non-storm-related damage. The claim was denied because (1) the damage did not exceed the deductible and (2) State Farm had already paid for a full roof replacement.
PROCEDURAL HISTORY
State Farm filed motion for summary...
It is Fraud to Make the Same Claim Twice
Read the full article at https://www.linkedin.com/pulse/fraud-make-same-claim-twice-barry-zalma-esq-cfe-c4g8c and at https://zalma.com/blog.
Chutzpah: After Being Paid for a New Roof Insured Makes Second Claim For Same Damages
Post number 5347
No One is Entitled to be Paid for the Same Loss Twice
In Mohammed Ali Khalili v. State Farm Lloyds, No. 14-25-00611-CV, Court of Appeals of Texas (April 30, 2026) Khalili maintained a State Farm Lloyds homeowners insurance policy for decades. In 2008 he filed a roof-damage claim; State Farm paid him to replace the entire roof (shingles and gutters). Khalili never replaced the roof and repeated his claim.
BACKGROUND
In 2021 he filed a second roof claim. State Farm’s inspectors found the roof “very old” with extensive non-storm-related damage. The claim was denied because (1) the damage did not exceed the deductible and (2) State Farm had already paid for a full roof replacement.
PROCEDURAL HISTORY
State Farm filed motion for summary...
What Must be Done after Notice of a Claim is Received by the Insurer
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A first party property policy does not insure property: it insures a person, partnership, corporation or other entity against the risk of loss of the property. Before an insured can make a claim for indemnity under a policy of first party property insurance the insured must prove that there was damage to property the risk of loss of which was insured by the policy. The obligation imposed on the insured ...
