ZIFL – Volume 30, Issue 7 – April 1, 2026
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5314
Posted on April 1, 2026 by Barry Zalma
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 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/ This issue contains the following articles about insurance fraud:
No One is Above the Law – Not Even a Police Officer
Police Officer Convicted for Fraud in Reporting an Accident Affirmed
Police Officer Should never Lie about Results of Chase
In State Of Ohio v. Anthony Holmes, No. 115123, 2026-Ohio-736, Court of Appeals of Ohio, Eighth District, Cuyahoga (March 5, 2026) a police officer appealed criminal conviction as a result of lies about a high speed chase.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
There is No Honor Among Thieves
Convicted Fraudsters Try to Cheat Each Other
After failing to defraud insurers about the loss of a diamond ring the two admitted fraudsters sought possession of the seized ring which was neither lost nor stolen but was seized by the state.
In State Of North Carolina v. Kevin Ray Reece and Debra Lee Goldman, No. COA25-569, Court of Appeals of North Carolina (March 18, 2026) two fraudsters disputed the ownership of a platinum-banded diamond ring seized during a criminal investigation as the subject of Insurance Fraud.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Failure to Provide Well-Pled Facts Defeats Most of Action
ERISA Saves Fraudulent Claims Suit
Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity
In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, managed the billing for Genesis.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
CRIME DOESN’T PAY, IT COSTS
No Right to Recover Allegedly Lost Jewelry When You Defrauded Your Insurer
Fraudulent Claims Defeated by Great Investigation
In The Cincinnati Insurance Company v. Zachary M. Zeltzer, Civil Action No. 25-2687, United States District Court, D. New Jersey (March 11, 2026) Plaintiff The Cincinnati Insurance Company issued an insurance policy to Defendant Zachary M. Zeltzer covering, among other things, jewelry. On September 3, 2021, Defendant submitted a claim reporting the loss of four jewelry items while vacationing in Italy.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Health Insurance Fraud Convictions
Arizona Cardiology Group Paying $4.75M Over Unnecessary Vein Procedure Allegations
Tri-City Cardiology, P.C., a physician group based in the metro area of Phoenix, and three physicians are paying the sum to resolve allegations that they violated the False Claims Act by performing the procedures.
The cardiology business and three physicians in Arizona were ordered to pay $4.75 million to resolve allegations they performed medically unnecessary vein ablations.
Read the following article and dozens more convictions and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
SPECULATION ABOUNDS ABOUT JAIL TIME THE LOUISIANA STAGED TRUCK ACCIDENT ATTORNEYS WILL RECEIVE AFTER A GUILTY VERDICT
Some Suggest The Maximum Is Possible As Federal Judge Expresses Serious Concerns About Defendants’ Actions
Sentencing of the two attorneys convicted in Operation Sideswipe is set for July.
Attorneys Vanessa Motta and Jason Giles were convicted in the U.S. District Court for the Eastern District of Louisiana on a variety of mail fraud, wire fraud and witness tampering charges connected to the scheme where a car full of passengers would slam into a truck in an effort to reap insurance payouts.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Other Than Health Insurance Fraud Cases
Oklahoma Insurance Producer Has License Revoked Following Investigation
Leslie Clark, a resident insurance producer from Stigler, Oklahoma, following an investigation led by its Anti-Fraud Uni was fined and her license was revoked by the Oklahoma Insurance Department (OID) announced it has
On Feb. 11, 2026, a show-cause hearing was held at OID’s offices before an independent examiner, at which Clark failed to appear. Clark was found to have improperly withheld and misappropriated 18 cash receipts totaling $7,269.38 from consumer premium payments.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
The Three Laws of Robotics
From Iassac Asimov’s book, I Robot
Dr. Asimov presented the laws in his fictional “Handbook of Robotics, 56th Edition, 2058 A.D.” are:
1. A robot may not injure a human being or, through inaction, allow a human being to come to harm.
2. A robot must obey the orders given it by human beings except where such orders would conflict with the First Law.
3. A robot must protect its own existence as long as such protection does not conflict with the First or Second Law.
Hopefully to be understood by those using Artificial Intelligence in the insurance industry replacing the words “human beings” with the “insureds.”
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
LITIGATION PRIVILEGE DEFEATS DEFAMATION SUITS
ABSOLUTE IMMUNITY FOR COMPLAINTS TO DMV
Complaints Filed By The Defendants With The Department Of Motor Vehicles Were Entitled To Absolute Immunity
In Modzelewski’s Towing & Storage, Inc., et al. v. Government Employees Insurance Company et al., No. AC 47933, Court of Appeals of Connecticut (March 24, 2026) Modzelewski’s Towing & Storage, Inc., Chris’ Auto Clinic, LLC, MyHoopty.com, LLC, and Farmington Auto Park, LLC, initiated an action seeking damages for tortious interference with business expectancies and other relief. The dispute arose after complaints were filed against them by Government Employees Insurance Company (GEICO) and individual defendants John P. Vaz and Patrick Capri with the Connecticut Department of Motor Vehicles. The plaintiffs alleged that these complaints interfered with their business relationships.
Barry Zalma
Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455.
Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
Read the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Arsonist Tried To Represent Himself, Failed, and Sought Habeas Relief
Post number 5357
Read the full article at https://www.linkedin.com/pulse/he-who-acts-his-own-lawyer-has-idiot-client-barry-zalma-esq-cfe-d4bwc, See the full video at and at and at https://zalma.com/blog.
Karacson’s Arson for Profit Attempt Required Skill & Experience to Succeed
In Steve Ellis Karacson v. David Shaver, Warden, No. 25-1089, United States Court of Appeals, Sixth Circuit (May 20, 2026) Steve Karacson was convicted in Michigan state court of arson and insurance fraud after evidence showed he burned his own insured home. Investigators found multiple points of origin, gasoline odor, and evidence tying him to the scene, including cell-phone location data and a receipt showing he had purchased a gas can and gloves shortly before the fire.
FACTS
Karacson initially had appointed counsel, but his relationships with both appointed attorneys ...
Foolish to Repeatedly Disobey Court Orders
All That Remains For Trial Is Plaintiff’s Damages On Each Of These Claims And Establishing Proximate Causation Of Those Damages.
Post number 5348
See the full video at and at and at https://zalma.com/blog plus 5300 posts.
In Linh Wang v. Esurance Insurance Company, No. C24-0447-JCC, United States District Court, W.D. Washington, Seattle (May 1, 2026) John C. Coughenour, United States District Judge, found that throughout this case, culminating with its briefing on Plaintiff’s renewed motion and that Defendant has subjected Plaintiff to unnecessary motion practice for clearly discoverable information and made dubious representations (including to the Court).
FACTUAL BACKGROUND
This case involves an underinsured/uninsured motorist insurance bad faith claim arising from a 2017 motor vehicle collision. The plaintiff, Linh Wang, alleges that Esurance Insurance ...
The Right to Negotiate with Insurer is Not an Assignment of Claims
Post number 5347
Read the full article at https://www.linkedin.com/pulse/ambiguous-contract-repair-assignment-barry-zalma-esq-cfe-2xppc, see the full video at https://rumble.com/v79is1s-ambiguous-contract-to-repair-not-an-assignment.html and at and at https://zalma.com/blog plus more than 5300 posts.
Nebraska Requires an Actual Assignment to Allow Contractor to Sue Insurer
In Millard Gutter Company, a corporation doing business as Millard Roofing and Gutter v. Farmers Mutual Insurance Company of Nebraska, also known as Farmers Mutual Insurance, also known as Farmers Mutual, No. A-24-818, Court of Appeals of Nebraska (May 5, 2026) Millard sued Farmers as an assignee of Jane Anzalone who had hired Millard Gutter to repair the roof of her home and agreed to allow Millard Gutter to coordinate with her insurer, Farmers Mutual, concerning reimbursement for repairs authorized under her insurance policy.
FACTUAL BACKGROUND
In ...
Court Allows itself to be Abused by Convicted Murderer and Insurance Fraudster
A Prisoner Has a Limited Right to file a Habeas Petition but Must do so Properly
Post number 5387
Posted on July 6, 2026 by Barry Zalma
Court Allows itself to be Abused by Convicted Murderer and Insurance Fraudster
A Prisoner Has a Limited Right to file a Habeas Petition but Must do so Properly
Post number 5387
In Tami Duvall v. State Of Indiana, No. 1:25-cv-01239-SEB-TAB, United States District Court, S.D. Indiana, Indianapolis Division (July 1, 2026) Indiana prisoner Tami Duvall filed a habeas petition under 28 U.S.C. § 2254 challenging her 2011 Indiana convictions for murder, insurance fraud, and obstruction of justice.
Law:
Federal Rule of Civil Procedure 15(a) governs amendment of pleadings, allowing amendment as of course within specified time limits and otherwise permitting amendment with leave of court when justice so requires.
Federal Rule of Civil Procedure 12(f) permits the Court to strike redundant matter. Rule 5 of the Rules ...
It is a Crime to Lie to Your Insurer That Accident Happened After Policy Inception
Post number 5386
Posted on July 3, 2026 by Barry Zalma
Conviction for Fraud Affirmed Because Evidence Overwhelming
In State Of Washington v. Saleem Mumin Robinson, No. 87244-3-I, Court of Appeals of Washington, Division 1 (June 29, 2026) Saleem Robinson was involved in an automobile collision on May 18, 2021. The other driver, Mohamed Waggeh, photographed Robinson’s documents and later reported the collision to GEICO, identifying the time as approximately 12:40 p.m.
That same day, at 6:06 p.m., more than five hours after the accident, Robinson purchased Progressive insurance for the vehicle involved in the collision.
The next morning, Robinson called Progressive to report the claim and stated that the accident occurred around 6:15 p.m. Progressive recorded that call without advising Robinson that it was being recorded. Progressive later conducted a special investigative unit investigation the claim because it was submitted shortly ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
