Post 5254
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Help a Person Commit Insurance Fraud & Go to Jail
Guilty of Tampering With Evidence by Hiding it in Garage
In State Of Montana v. Lila Lynn Lord, 2025 MT 302, No. DA 24-0343, Supreme Court of Montana (December 30, 2025) Lila Lord (Lord) appealed her conviction for Tampering with Evidence following a jury trial in the Seventh Judicial District Court, Richland County. The case centered on a staged burglary in Sidney, Montana, orchestrated by Marie Chris Entzel with the intent to collect insurance proceeds to cover her son’s legal fees. Entzel recruited several individuals — including David Skaw, Lawrence Pohl, Laurie McGregor, and the defendant, Lila Lord — to assist in removing valuable items from her home, causing property damage and theft of items such as an enclosed trailer, boat and trailer, refrigerator, pistol, and television.
Entzel’s husband was away and unaware of the plan; upon his return, he reported the incident to police, prompting an investigation. Entzel was charged with insurance fraud and false reports, but not with tampering with evidence. Lord was charged with conspiracy to commit insurance fraud and tampering with evidence for allegedly taking and hiding stolen items at her residence while knowing an official investigation was underway.
FACTUAL BACKGROUND
The State alleged that Entzel, Skaw, Lawrence Pohl (Pohl), Laurie McGregor, and Defendant Lord, among others, were involved in the staged burglary.
The State called Entzel, Skaw, and Officer Norby to testify. Although Entzel and Skaw had both entered guilty pleas before Lord’s trial, neither was compelled to testify as part of their plea agreements. By the time Skaw had returned 1-2 hours later, Lord was done taking apart the refrigerator.
Lord, Skaw, and Entzel loaded the refrigerator’s doors into Lord’s vehicle and the body of the refrigerator into Entzel’s truck. Entzel testified that Lord was fully aware of the insurance fraud scheme.
The jury found Lord not guilty of conspiracy to commit insurance fraud, and guilty of tampering with evidence.
LEGAL ISSUES:
On appeal, Lord challenged her conviction for tampering with evidence, raising several legal questions:
1. whether the District Court erred in denying her proposed accomplice jury instruction;
2. whether the court wrongly denied her request to allow a witness (Pohl) to testify remotely by video; and
3. whether the court erred by denying her motion for a directed verdict based on insufficient corroboration of accomplice testimony.
These issues focus on the fairness of trial procedures and the sufficiency of evidence supporting her conviction.
Did The District Court Err By Denying Defendant’s Request For A Witness To Testify By Video?
Two days before trial, Lord moved the District Court for leave for witness Lawrence Pohl to appear and testify by video, which was denied. Because Lord was ultimately acquitted of the conspiracy to commit insurance fraud charge, she suffered no prejudice from Pohl’s failure to testify.
Did The District Court Err By Denying Defendant’s Directed Verdict Motion Based On Insufficient Corroboration Of An Accomplice’s Testimony?
The Court of Appeals concluded that Entzel and Lord were not accomplices for purposes of an accomplice instruction, given Lord’s innocence defense, and as such, the State was not burdened to corroborate Entzel’s testimony. Based on the court’s review of the record it found there was sufficient evidence to support the District Court’s denial.
Lord admitted when police officers informed Lord that Entzel’s boat had been seen in her garage, Lord replied that she was at least aware a boat had been placed in her garage.
Construing the evidence in a light most favorable to the State, a rational jury could have found from this direct and circumstantial evidence that Lord had concealed or tampered with evidence, that is, Entzel’s property, while knowing that an official proceeding or investigation was about to be instituted.
ZALMA OPINION
It takes a great amount of gall for a person to assist in a criminal act – taking possession of property the defendant knew would be claimed stolen as part of an insurance fraud scheme. Lord was only convicted of taking possession of the property – a refrigerator and a boat – to assist the insurance fraud scheme. To then appeal wanting to make the originator of the crime help her avoid conviction was, as it should be, unsuccessful.
(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 ...
