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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