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March 13, 2026
Fraudster Fails as a Jail House Lawyer

Chutzpah of Fraud Perpetrator Still Gets 36 years in Prison

Post number 5303

Read the full article at https://www.linkedin.com/pulse/fraudster-fails-jail-house-lawyer-barry-zalma-esq-cfe-araye and at https://zalma.com/blog plus more than 5200 posts.

Prisoner Should Know Better Than Representing Himself

In The People v. Roderick Nathaniel Washington, B330868, California Court of Appeals, Second District, Eighth Division (March 5, 2026) Roderick Nathaniel Washington was convicted by a jury on numerous counts related to credit card and unemployment insurance fraud.

The investigation revealed that Washington orchestrated two main types of fraud. The first involved credit cards: police searches at the residences of Washington’s girlfriend and his daughter uncovered hundreds of credit profiles, personal identifying information, mail addressed to Washington, fraudulent licenses and credit cards, and forged reports.

FACTUAL BACKGROUND

Bank Fraud

Washington opened multiple accounts in the names of others, including deceased individuals, and then reported fraudulent activity to avoid paying debts, eventually causing nearly half a million dollars in losses to Synchrony Financial. Washington was found to have information on about 90 Synchrony accounts. Investigation revealed Washington had opened accounts in the name of other people, including dead ones. After opening these accounts, he would claim there was fraudulent activity on the account in order to avoid paying the debt on that account. The company or bank would then provide a new account, which Washington would also fail to pay off. Washington caused just under half a million dollars in loss to bank and credit card company Synchrony Financial.

Unemployment Insurance Fraud

The second type of fraud Washington committed involved California’s Employment Development Department, which runs the state’s unemployment and disability insurance program. The Department relaxed standards during the covid pandemic to address the sudden increased need. After getting through the crisis period, the Department began investigating a series of applications for unemployment benefits all sent from the same IP address.
CONVICTIONS

The jury convicted Washington of:

1. two counts of theft by false pretenses in violation of section 532, subdivision (a);
2. one count of possession of a forged driver’s license in violation of section 470(b);
3. two counts of possession of multiple person’s personal identifying information with intent to defraud in violation of section 530.5, subdivision (c)(3);
4. one count of preparing false documentary evidence in violation of section 134;
5. three counts of unlawful transfer of personal identifying information in violation of section 530.5, subdivision (d)(1);
6. four counts of possession of personal identifying information with intent to defraud in violation of section 530.5, subdivision (c)(2); and
7. 33 counts of unemployment insurance fraud in violation of Unemployment Insurance Code section 2101, subdivision (a). With regard to the unemployment insurance fraud counts, the jury found the loss from the offenses exceeded $500,000 and, after a bifurcated trial, there existed factors in aggravation.

The trial court sentenced Washington to three years on the unemployment insurance fraud count and a consecutive five years for the loss enhancement. The court sentenced Washington to consecutive eight-month terms on the other 32 unemployment insurance fraud counts and 11 of the other counts. In total, the court sentenced Washington to 36 years and eight months in prison.

LEGAL ISSUES

Washington attempted to defeat the testimony of the arresting officer. The court reviewed the case pursuant to Pitchess v. Superior Court (1974) 11 Cal.3d 531, which governs the disclosure of law enforcement personnel records when issues of officer credibility or misconduct are raised.

ANALYSIS

Washington appealed the judgment on several grounds, including requesting review of the trial court’s determinations under Pitchess. The appellate court examined the evidence collected, including the extensive fraudulent materials and the significant losses to financial institutions, and considered whether the trial court properly handled the Pitchess motions and other claims raised on appeal.

DISCUSSION

The Court of Appeal granted Washington’s request to review the trial court’s Pitchess determinations. After review, the court affirmed the judgment, finding no reversible error in the handling of the evidence, the application of law, or the review of law enforcement records. The appellate panel concluded that the evidence supported the convictions and that Washington’s legal challenges did not warrant reversal.

The trial court noted Washington’s repeated and demonstrated inability to follow the court’s rules, noted that sometimes legislative inaction without more does not signify approval, and this was especially true because precedent could not be applied retroactively. Rejection was appropriate to misconduct occurring like Washington’s acts here.

ZALMA OPINION

Fraudsters, like Washington, continue to prove that their criminal conduct was egregious and attempt to avoid jail with hired lawyers or acting as their own lawyer. Although Washington was a skilled criminal his activity as his own attorney established pure incompetence and an ability to annoy a trial judge beyond restraint. He deserves, and will serve, the 36 years and 8 months in prison.

(c) 2026 Barry Zalma & ClaimSchool, Inc.

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May 01, 2026
Zalma’s Insurance Fraud Letter – May 1, 2026

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 ...

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April 30, 2026
The Efficient Proximate Cause Doctrine Saves a Claim

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 ...

00:08:38
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April 29, 2026
Breach of a Specific Condition Precedent Is a Complete Defense

Breach of a Specific Condition Precedent Is a Complete Defense

See the video at and at and at https://zalma.com/blog plus more than 5300 posts.

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 ...

00:11:27
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12 hours ago

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...

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12 hours ago

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...

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April 30, 2026
Investigation of First Party Property Claims

What Must be Done after Notice of a Claim is Received by the Insurer

Read the full article at https://lnkd.in/gzvvdkMZ and at https://zalma.com/blog.

Below you will read from this post until you reach the the end of this blog post as the free part of an Excellence in Claims Handling post. To read the full article and receive all articles for members of Excellence in Claims Handling you should consider joining as a paid member to get full access to articles for members only, to our news, analysis, insurance coverage, claims, insurance fraud and insurance webinars, by clicking at the subscription link below.

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 ...

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