ZIFL – Volume 30, Issue 10 – May 15, 2026
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5352
Read the full article at https://www.linkedin.com/pulse/zalmas-insurance-fraud-letter-may-15-2026-barry-zalma-esq-cfe-iulwc and at https://zalma.com/blog plus more than 5300 posts.
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:
Crime Doesn’t Pay
FELONIOUS PUBLIC ADJUSTER SUED FOR FEES ALLEGEDLY EARNED AS PART OF HIS CRIMINAL CONDUCT
Criminal May NotSue in Name of Corporation
In Andrew J Mitchell v. Pandit Law Firm, LLC, Civil Action No. 3:26-cv-00095, United States District Court, S.D. Texas, Galveston Division (April 30, 2026) the magistrate judge issued, on his own motion, a sua sponte memorandum and recommendation addressing whether Mitchell, a convicted felon who abused his license as a public insurance adjuster, concluding that he may not proceed pro se.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
The False Claims Act & Insurance
RECENT DEVELOPMENTS ON FCA INSURANCE COVERAGE
Coverage for FCA Investigations & Quit Tam Suits
Because qui tam complaints are often, if not always, filed under seal, insureds and insurers frequently first learn of a potential False Claims Act (FCA) matter through a civil investigative demand (CID).
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
MORE MCCLENNY MOSELEY & ASSOCIATES ISSUES
This is ZIFL’s forty-third installment of the saga of McClenny, Moseley & Associates and its problems with the federal courts in the State of Louisiana and what appears to be an effort to profit from what some Magistrate and District judges indicate may be criminal conduct to profit from insurance claims relating to hurricane damage to the public of the state of Louisiana.
Mitchell, a public adjuster found guilty of multiple counts of insurance fraud apparently joined with the law firm whose honor has been questioned in Louisiana and Texas were sued for his less than honorable work in Andrew J Mitchell v. John Mcclenny, et al., Defendants, Civil Action No. 3:26-cv-00092, United States District Court, S.D. Texas, Galveston Division (April 30, 2026)
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
From the Coalition Against Insurance Fraud
The Coalition Against Insurance Fraud reported at https://www.acfe.com/acfe-insights-blog/blog-detail?s=double-whammy-health-care-fraud in part that:
In 2025, the National Health Care Fraud Takedown resulted in criminal charges against 324 defendants for schemes involving more than $14.6 billion in intended losses. While the scheme netted nearly 100 medical professionals, one key aspect that escaped most news headlines was their involvement in multiple fraud schemes.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
Health Insurance Fraud Convictions
National Health Care Fraud Takedown Results in 324 Defendants Charged in Connection with Over $14.6 Billion in Alleged Fraud
Largest Justice Department Health Care Fraud Takedown in History More than Doubles Prior Record of $6 Billion
The 2025 National Health Care Fraud Takedown, which resulted in criminal charges against 324 defendants, including 96 doctors, nurse practitioners, pharmacists, and other licensed medical professionals, in 50 federal districts and 12 State Attorneys General’s Offices across the United States, for their alleged participation in various health care fraud schemes involving over $14.6 billion in intended loss. The Takedown involved federal and state law enforcement agencies across the country and represents an unprecedented effort to combat health care fraud schemes that exploit patients and taxpayers.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
The Department Of Justice Filed A Statement Of Interest In A Lawsuit Filed Against State Farm
The case, Ferrier v. State Farm Fire and Casualty Company, is pending in the Superior Court of Los Angeles County. It was brought by 60 homeowners who lost their homes in the wildfires. They allege that the defendants, which include 16 homeowners insurance companies, conspired to cancel their fire insurance policies in the years leading up to the fires. The homeowners say they were forced to obtain insurance from the California FAIR Plan, which offers less coverage, resulting in higher out-of-pocket expenses for rebuilding.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
The Fraud Division Announces Enforcement Actions from Across the Country Representing Nearly $1 Billion in Fraud
Friday, May 8, 2026: The Justice Department’s National Fraud Enforcement Division continued to advance its mission to fight fraud and protect taxpayers. Just on Monday, two men were sentenced to 151 months and 36 months in prison, respectively, for their roles in submitting over $522 million in fraudulent claims for medically unnecessary genetic tests in a scheme to defraud Medicare, Medicaid, and private health insurance companies.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
ACFE Report to the Nations
The Association of Certified Fraud Examiners (ACFE) is excited to share Occupational Fraud 2026: A Report to the Nations, the 14th edition of the largest and most comprehensive study on the costs and effects of occupational fraud.
Analyzing data from 2,402 real fraud cases across 143 countries and territories, the report provides a global view of how fraud is committed, detected and prevented within organizations in both the public and private sectors.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
DOJ Announces Highest-Ever Annual False Claims Act Recoveries: Over $6.8 Billion in Fiscal Year 2025
The US Department of Justice (DOJ) on January 20, 2026 announced that recoveries from False Claims Act (FCA) settlements and judgments in fiscal year 2025 exceeded $6.8 billion, the highest annual amount in FCA history and more than double the 10-year average a small part of the $308 billion a year reported by the Coalition Against Insurance Fraud.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
California Takes Legal Action Against State Farm After Investigation Finds Widespread Mishandling Of LA Wildfire Claims
Expedited investigation finds widespread violations affecting potentially thousands of wildfire survivors; penalties sought are the largest pursued after a disaster this century.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
The U.S Treasury Department Targets Fraud Schemes Exploiting Government Health Care Benefits
On March 30, 2026, in support of President Trump’s pledge to combat fraud, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory urging financial institutions to be vigilant about fraud schemes targeting government health care benefit programs such as Medicare and Medicaid.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
Other Than Health Insurance Fraud Cases
This Week in Fraud: DOJ’s New Fraud Division Announces Numerous Fraud Enforcement Actions and a New Strike Force to Investigate and Prosecute Fraud on the West Coast
The National Insurance Crime Bureau Asks Everyone to Report Fraud
The Justice Department’s National Fraud Enforcement Division continued to advance its mission to fight fraud and protect taxpayers this week.
Read the full article and the full issue at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.pdf
Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455. Barry Zalma, Esq., CFE, now limits his practice to service as an insurance consultant specializing in insurance coverage, insurance claims handling, insurance bad faith and insurance fraud almost equally for insurers and policyholders. He also serves as an arbitrator or mediator for insurance related disputes. Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
See the full May 15, 2026 issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-05-15-2026-1.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 ...
Qui Tam Case Without Evidence to Prove Fraud Fails
Post number 5369
Read the full article at https://www.linkedin.com/pulse/qui-tam-insurer-contended-defrauded-barry-zalma-esq-cfe-pgfgc and at https://zalma.com/blog plus more than 5550 posts.
In People Of The State Of California Ex Rel. Heath & Yuen, APC v. Silver Bird Auto Leasing, LLC et al., B342847, California Court of Appeals, Second District, Eighth Division (June 5, 2026) Heath & Yuen, APC defended parties in an automobile collision case involving a McLaren and a tour van. After that case settled for $25,000, the firm filed a qui tam action under California’s Insurance Frauds Prevention Act (IFPA) against Silver Bird Auto Leasing, LLC, X-Law Group, PC, and Filippo Marchino. The firm alleged three fraudulent acts in the underlying litigation:
1. the complaint falsely stated the McLaren was making a “legal turn,”
2. respondents produced a fraudulent repair bill/estimate, and
3. respondents failed to disclose Marchino’s GEICO insurance and its payment for repairs....
Full Faith and Credit Act Controlled
Read the full article at https://lnkd.in/evHXiiFE and at https://zalma.com/blog.
Posted on June 9, 2026 by Barry Zalma
Post number 5368
Posted on June 9, 2026 by Barry Zalma
In Prime Insurance Company, Inc. v. Medicab Transportation, LLC, Jason Rhodes, and Dale Johnson v. Prime Insurance Company, Inc and Prime Property & Casualty Insurance, Inc. No. 2:24-cv-421-SPC-KRH, United States District Court, M.D. Florida, Fort Myers Division (June 3, 2026) Medicab, a paratransit company, bought two policies in 2021: a Business Auto Policy from PPCI and a Commercial Liability Policy from Prime. Both policies, as originally written, appeared to cover injuries arising from loading and unloading patients from Medicab vans.
After a patient, Margaret St. Aubin, fell while being unloaded from a van and suffered injuries, her Estate made a $1 million demand. Prime and its claims administrator concluded that the Commercial Policy’s loading/unloading language had been included by mutual mistake, because...
Full Faith and Credit Act Controlled
Read the full article at https://lnkd.in/evHXiiFE and at https://zalma.com/blog.
Posted on June 9, 2026 by Barry Zalma
Post number 5368
Posted on June 9, 2026 by Barry Zalma
In Prime Insurance Company, Inc. v. Medicab Transportation, LLC, Jason Rhodes, and Dale Johnson v. Prime Insurance Company, Inc and Prime Property & Casualty Insurance, Inc. No. 2:24-cv-421-SPC-KRH, United States District Court, M.D. Florida, Fort Myers Division (June 3, 2026) Medicab, a paratransit company, bought two policies in 2021: a Business Auto Policy from PPCI and a Commercial Liability Policy from Prime. Both policies, as originally written, appeared to cover injuries arising from loading and unloading patients from Medicab vans.
After a patient, Margaret St. Aubin, fell while being unloaded from a van and suffered injuries, her Estate made a $1 million demand. Prime and its claims administrator concluded that the Commercial Policy’s loading/unloading language had been included by mutual mistake, because...
