Jon Woods is an attorney who specialized in workers’ compensation law and formed a law firm exclusively dedicated to representing employees. Woods began his firm in 2001. By 2011 he had hired between 15 and 25 employees to work at his law firm. Up to that point, Woods marketed his services using print, radio, and television advertisements.

Edgar Gonzales owned a copy services business called USA Photocopy in the City of Santa Ana. Woods began working with USA Photocopy in approximately 2007. USA Photocopy, among other things, provided subpoena services for workers’ compensation attorneys.USA Photocopy typically billed the insurance company for the services.

In 2011, Woods met Carlos Arguello. Arguello ran several companies, the primary business being a marketing company called, at one point, Centro Legal Internacional (his companies went by several different names). Ostensibly, Arguello’s company offered advertising services to obtain workers’ compensation clients. Arguello’s company advertised in print, radio, television, and online. At one point, Arguello’s company was distributing 4,000,000 fliers per month. Arguello would promise attorneys a certain number of clients per month, depending on how much the attorney was willing to pay per month.

In many instances Arguello’s company would send a non-lawyer representative to the caller’s house to sign a legal services agreement, and afterward the case would be assigned to one of the lawyers who had retained Arguello’s services. Woods received clients this way.

Arguello had agreements with certain doctors. When Arguello would sign up a client for legal services, he would immediately schedule an appointment for the client with a doctor in his network. Woods allowed Arguello to employ his network of doctors for the cases sent to Woods. This was central to Arguello making a profit from his enterprise.

Arguello also owned and operated copy services businesses. Those included C&E Technology and Professional Documents Management. Using Arguello’s copy service for subpoenas was a condition of engaging his advertising service.

Woods worked with Arguello through 2017. Over the course of their relationship, Woods paid Arguello’s businesses $1,425,000 in fees for advertising services.

Arguello pleaded guilty to federal criminal charges related to worker’s compensation fraud and was sentenced to four years in federal prison, which he began serving in July 2019. Arguello also pleaded guilty to charges brought by the Orange County District Attorney. Part of the factual basis for his plea involved a conspiracy with Woods. Arguello signed a cooperation agreement in which he agreed to testify truthfully.

In 2019, the Orange County District Attorney filed an amended information alleging 37 felony counts against Woods. In April 2019, the jury was unable to reach a unanimous decision, and Woods’s first trial ended in a mistrial. The jury was split 8–4 in favor of guilt. In Woods’s second trial in August 2022, the jury found Woods guilty on all counts and found the white collar enhancement allegation to be true. Woods’s total prison sentence was four years. Woods was ordered to pay restitution in the amount of $701,452. Woods appealed.

The Court of Appeal reversed his conviction on counts 5-37, the restitution order in favor of insurance companies and the white collar enhancement in the published case of People v Woods – G061948 (March 2025).

On appeal Woods contends that the Williamson rule (In re Williamson (1954) 43 Cal.2d 651) precluded convictions on counts 5 through 37. Broadly speaking, the Williamson rule states that where the Legislature has defined a specific crime with a lesser punishment, the conduct described by that crime may not be charged as a more general crime with a harsher punishment.

The idea is that by identifying specific conduct, the Legislature has expressed an intent that the conduct by punished at the lower level. Here, counts 5 through 37 were charged under Penal Code section 550, subdivision (b)(3), a felony, which criminalizes concealing or withholding information from an insurance company that would affect an entitlement to an insurance benefit.

Woods contends that his conduct is covered by a more specific statute, Labor Code section 139.32. That section makes it a misdemeanor to refer work to third-party servicers in exchange for compensation of any sort.

The Court of Appeal agreed with Woods that the Williamson rule applies under these circumstances.