Was Insurance Fraud Attempted to Avoid Paying Child Support
No Matter How Contentious Divorce Seldom Charges the Parties with Fraud
Post number 5358
In Katherine Jane Macdonald v. Bryce Inglis Macdonald v. Mckenzie Cronk, LLC, and Denison Cronk, LLC, No. COA24-759, Court of Appeals of North Carolina (May 6, 2026).
The marital estate included multiple real properties, safe deposit boxes, insurance proceeds, rental income, retirement accounts, and two LLCs — Denison Cronk, LLC and McKenzie Cronk, LLC (Patio Playground).
FACTS
The court concluded that Wife’s actions “were undertaken knowingly and voluntarily to conceal income for the Patio Playground and in an effort to conceal potential insurance fraud.”
On the insurance proceeds, she claimed that because the checks were deposited into marital accounts, the court could not find she personally “received” them.
Law
Equitable distribution orders are reviewed to determine whether the findings are supported by competent evidence and whether those findings support the judgment; the actual distribution is reviewed for abuse of discretion.
Analysis
The Court of Appeals held that the trial court’s detailed findings regarding safe deposit box cash, insurance proceeds, diverted rental income, business goodwill, real property values, retirement account valuation, and the Camaro valuation were supported by competent evidence or binding stipulations.
On child support, however, the court found that two components of Husband’s income — his Social Security amount and 401(k) withdrawal amount — were not supported by evidence in the record.
Discussion
This case emphasizes the deference appellate courts give trial judges in equitable distribution disputes.
Conclusion
The Court of Appeals affirmed the equitable distribution and sanctions portions of the trial court’s order, but vacated in part and remanded the child support order because the findings concerning Husband’s Social Security and 401(k) income were unsupported by the record.
ZALMA OPINION
When I was a new lawyer I was assigned to deal with several divorce cases before I changed to an insurance law firm. The work was not pleasant and the parties were often at each others throats. If the court believed insurance fraud was attempted the judges in the Court of Appeals should have reported their findings to the appropriate prosecutor.
(c) 2026 Barry Zalma & ClaimSchool, Inc.
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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 ...
Plaintiff May Try Again to get a Judgment
Posted on May 22, 2026 by Barry Zalma
Just Because a Defendant Defaults Evidence is Needed to get a Judgment
Even on a Default Motion the Plaintiff Must Do More Than Rely on Conclusory Allegations.
Post number 5356
The Commissioners Of The State Insurance Fund v. Capcon Construction Industries Corp., Capcon Construction Supply Corp., Jab Masonry Corp., Agra Masonry Inc., Agra Industries Usa Corp, A & A Masonry Corp., Alexander Shvartsberg, Darren Caputo, Maryann Furman, Index No. 452680/2024, MOTION SEQ. No. 003, 2026 NY Slip Op 31767(U), Supreme Court, New York County (April 20, 2026)
FACTS
The Commissioners of the State Insurance Fund (SIF) had already obtained two judgments for unpaid workers’ compensation insurance premiums: one against A\&A Masonry Corp. and another, much larger one, against Agra Masonry Inc. SIF then brought this action against several related corporations and individuals, alleging that they all operated as a single de facto enterprise and that assets had ...
Plaintiff May Try Again to get a Judgment
Posted on May 22, 2026 by Barry Zalma
Just Because a Defendant Defaults Evidence is Needed to get a Judgment
Even on a Default Motion the Plaintiff Must Do More Than Rely on Conclusory Allegations.
Post number 5356
The Commissioners Of The State Insurance Fund v. Capcon Construction Industries Corp., Capcon Construction Supply Corp., Jab Masonry Corp., Agra Masonry Inc., Agra Industries Usa Corp, A & A Masonry Corp., Alexander Shvartsberg, Darren Caputo, Maryann Furman, Index No. 452680/2024, MOTION SEQ. No. 003, 2026 NY Slip Op 31767(U), Supreme Court, New York County (April 20, 2026)
FACTS
The Commissioners of the State Insurance Fund (SIF) had already obtained two judgments for unpaid workers’ compensation insurance premiums: one against A\&A Masonry Corp. and another, much larger one, against Agra Masonry Inc. SIF then brought this action against several related corporations and individuals, alleging that they all operated as a single de facto enterprise and that assets had ...
Defaulting Fraud Perpetrator Lets Insurer Defeat Fraud
Post number 5355
Posted on May 21, 2026 by Barry Zalma
In Transamerica Life Insurance Company v. John Joseph Egan, et al., No. 25-cv-06167-JD, United States District Court, N.D. California (May 12, 2026) Transamerica Life Insurance Company issued John Egan a life insurance policy with a long-term care rider that covered in-home skilled nursing or other professional care if he qualified as chronically ill.
FACTUAL BACKGROUND
In 2023, Egan submitted a claim alleging severe pain, major loss of daily functioning, and limited mobility following an auto accident. Transamerica approved coverage and paid benefits based on those representations and repeated proofs of loss describing in-home care services. After later surveillance in 2024 and 2025 showed Egan working, driving, shopping, and otherwise functioning without visible impairment — and showed no evidence of in-home care — Transamerica concluded that the claim was fraudulent and filed suit.
Transamerica surveilled ...
