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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Insured Must Give Prompt Notice of Loss
Post 5256
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Once The Insured Knows There is Damage It is Obligated to Report the Loss to the Insurer
In Greater St. Stephen Ministries, Inc. v. Mt. Hawley Insurance Company, No. 24-cv-3130 (AS), United States District Court, S.D. New York (January 2, 2026) resolved a case brought by a church against an insurance company for denying coverage after Hurricane Ida. After discovery, the insurance company moved for summary judgment because it claimed the insured breached a material condition of the policy.
BACKGROUND
Greater St. Stephen Ministries, Inc., a church located in Louisiana, owned property that suffered damage from Hurricane Ida on August 29, 2021. The property was insured under a policy with Mt. Hawley Insurance Company, which required the insured to provide “prompt notice” of any loss or damage, ...
Insured Must Give Prompt Notice of Loss
Post 5256
Read the full article at https://lnkd.in/gBXRbKXD, see the video at https://lnkd.in/g4DKfUDz and at https://lnkd.in/g65V_RQ7 and at https://zalma.com/blog plus more than 5250 posts.
Once The Insured Knows There is Damage It is Obligated to Report the Loss to the Insurer
In Greater St. Stephen Ministries, Inc. v. Mt. Hawley Insurance Company, No. 24-cv-3130 (AS), United States District Court, S.D. New York (January 2, 2026) resolved a case brought by a church against an insurance company for denying coverage after Hurricane Ida. After discovery, the insurance company moved for summary judgment because it claimed the insured breached a material condition of the policy.
BACKGROUND
Greater St. Stephen Ministries, Inc., a church located in Louisiana, owned property that suffered damage from Hurricane Ida on August 29, 2021. The property was insured under a policy with Mt. Hawley Insurance Company, which required the insured to provide “prompt notice” of any loss or damage, ...
New Trial Because Jury Used Policy That Provides No Coverage to Assess Damages
Post 5255
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In Brown & Brown of Florida, Inc. v. Houligan’s Pub & Club, Inc., and Ormond Wine Company, LLC, Nos. 5D2024-2352, 5D2024-2458, Florida Court of Appeals (January 2, 2026) the Court of Appeals was faced with a case of first impression that involved damages from a hurricane that hit the East Coast of Florida almost a decade ago and the extent to which an insurance broker is responsible for paying for such damages.
The jury entered a verdict in favor of the insurance broker on the insured’s claim that it was negligent in failing to procure insurance, but it found in favor of the insured on claims of breach of fiduciary duty and negligent misrepresentation.
The insurance broker does not contest it breached its duties on these two claims, only ...
Court Must Follow Judicial Precedent
Post 5252
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Insurance Policy Interpretation Requires Application of the Judicial Construction Doctrine
In Montrose Chemical Corporation Of California v. The Superior Court Of Los Angeles County, Canadian Universal Insurance Company, Inc., et al., B335073, Court of Appeal, 337 Cal.Rptr.3d 222 (9/30/2025) the Court of Appeal refused to allow extrinsic evidence to interpret the word “sudden” in qualified pollution exclusions (QPEs) as including gradual but unexpected pollution. The court held that, under controlling California appellate precedent, the term “sudden” in these standard-form exclusions unambiguously includes a temporal element (abruptness) and cannot reasonably be construed to mean ...
Lack of Jurisdiction Defeats Suit for Defamation
Post 5250
Posted on December 29, 2025 by Barry Zalma
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He Who Represents Himself in a Lawsuit has a Fool for a Client
In Pankaj Merchia v. United Healthcare Services, Inc., Civil Action No. 24-2700 (RC), United States District Court, District of Columbia (December 22, 2025)
FACTUAL BACKGROUND
Parties & Claims:
The plaintiff, Pankaj Merchia, is a physician, scientist, engineer, and entrepreneur, proceeding pro se. Merchia sued United Healthcare Services, Inc., a Minnesota-based medical insurance company, for defamation and related claims. The core allegation is that United Healthcare falsely accused Merchia of healthcare fraud, which led to his indictment and arrest in Massachusetts, causing reputational and business harm in the District of Columbia and nationwide.
Underlying Events:
The alleged defamation occurred when United ...
Zalma’s Insurance Fraud Letter
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ZIFL Volume 29, Issue 24
Subscribe to the e-mail Version of ZIFL, it’s Free! https://visitor.r20.constantcontact.com/manage/optin?v=001Gb86hroKqEYVdo-PWnMUkcitKvwMc3HNWiyrn6jw8ERzpnmgU_oNjTrm1U1YGZ7_ay4AZ7_mCLQBKsXokYWFyD_Xo_zMFYUMovVTCgTAs7liC1eR4LsDBrk2zBNDMBPp7Bq0VeAA-SNvk6xgrgl8dNR0BjCMTm_gE7bAycDEHwRXFAoyVjSABkXPPaG2Jb3SEvkeZXRXPDs%3D
Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at http://zalma.com/zalmas-insurance-fraud-letter-2/
Zalma’s Insurance Fraud Letter
Merry Christmas & Happy Hannukah
Read the following Articles from the December 15, 2025 issue:
Read the full 19 page issue of ZIFL at ...
