Former Judge Israel Claustro served on the Orange County Superior Court from 2022 until his resignation on January 12, 2026. His departure from the bench was precipitated by federal criminal charges. On January 7, 2026, the U.S. Department of Justice filed charges against Claustro in U.S. v. Israel Claustro, No. 8:26-cr-00001-FWS (C.D. Cal.), for his role — before he became a judge — in a scheme to defraud the California Subsequent Injuries Benefits Trust Fund. The fraud did not involve his practice of law. Five days later, on January 12, 2026, Claustro pleaded guilty to one felony count of mail fraud and agreed to immediately resign from the bench. He had not yet been sentenced as of the date of the stipulation. According to the plea agreement, Claustro – who was an Orange County prosecutor at the time of the fraud – operated Liberty Medical Group Inc., a Rancho Cucamonga-based medical corporation, despite being neither a physician nor a medical professional as required under California law. One of Liberty’s employees was Dr. Kevin Tien Do, 60, of Pasadena, a physician who had served a one-year federal prison sentence after being convicted in 2003 of felony health care fraud. Because of this conviction, in October 2018, Do was suspended from participating in the California’s workers’ compensation program. Claustro was aware of Do’s prior criminal conviction and suspension from California’s workers’ compensation program. According to the plea agreement, Claustro admitted that he defrauded California’s Subsequent Injuries Benefits Trust Fund (SIBTF), a special fund administered by California’s workers’ compensation program to provide additional compensation to injured workers who already had a disability or impairment at the time of a subsequent injury. Specifically, Claustro paid Do more than $300,000 for preparing medical evaluations, medical record reviews, and med-legal reports after Do’s suspension. Claustro caused Liberty to mail these reports to California’s SIBTF, concealing that they were prepared by Do by listing other doctors’ names on the billing forms and reports. Based on these fraudulent submitted reports, Liberty received hundreds of thousands of dollars from SIBTF. The Commission also found that Claustro had executed his guilty plea agreement on December 8, 2025, yet failed to promptly report the criminal charges to the Commission on Judicial Performance as required by Canon 3D(3) of the Code of Judicial Ethics. Claustro and his counsel, Paul S. Meyer, entered into a Stipulation for Discipline by Consent with Commission Director-Chief Counsel Gregory Dresser under Commission Rule 116.5. Under the stipulation, Claustro admitted that the facts were true, accepted the legal conclusions, and waived any right to further proceedings — including formal proceedings before the Commission and review by the California Supreme Court. The Commission imposed a public censure and bar. Under Article VI, Section 18, subdivision (d) of the California Constitution, the Commission has authority to censure a judge for conduct prejudicial to the administration of justice that brings the judicial office into disrepute. The Commission concluded that Claustro's prebench felony fraud — a crime of moral turpitude — met that standard. Consistent with precedent, commission of a felony alone is a sufficient basis for censure and bar, regardless of the underlying facts of the crime. *See Censure and Bar of Former Judge Ronald C. Kline* (2006) p. 3; Cal. Const., art. VI, § 18, subd. (d); *Broadman v. Commission on Judicial Performance* (1998) 18 Cal.4th 1079, 1111–1112 ...

Glucagon-like peptide-1 receptor agonists (GLP-1 RAs) — including semaglutide (Ozempic, Wegovy), tirzepatide (Mounjaro), liraglutide, and dulaglutide — have become one of the most widely prescribed drug classes in the United States. Originally developed for type 2 diabetes, they now carry FDA approval for obesity and weight-related comorbidities. With over 40% of U.S. adults classified as obese per CDC data, and with obesity being a well-documented risk factor for complications in joint replacement and spine surgery, GLP-1 RAs are increasingly relevant to the injured worker population. More than half of patients undergoing total knee and hip arthroplasty meet criteria for obesity or morbid obesity, making preoperative weight management a frontline concern for orthopedic surgeons treating industrial injuries. Perioperative Risks: Aspiration and Gastric Motility GLP-1 medications slow gastric emptying — a therapeutic feature for appetite control that becomes a serious anesthetic hazard. The American Society of Anesthesiologists (ASA) has issued guidance recommending that patients on **daily-dose** GLP-1 therapy withhold the medication on the day of elective surgery, and patients on **weekly-dose** formulations withhold it for a full week prior. If a patient on GLP-1 therapy presents with gastrointestinal symptoms on the day of surgery, the ASA recommends either postponing surgery or proceeding with "[full stomach precautions](https://journals.lww.com/jbjsjournal/fulltext/2025/08200/glp_1_receptor_agonists_in_orthopaedic_surgery_.17.aspx)." Research presented at the American Academy of Orthopaedic Surgeons (AAOS) 2025 annual meeting in San Diego suggested an even more conservative window — stopping GLP-1s **14 days** before surgery to adequately reduce aspiration risk. Aspiration complications can include bronchial spasms, pneumonia, and death. In the trauma setting, where surgery cannot be delayed, surgeons should use point-of-care gastric ultrasound and full stomach precautions at the surgeon's discretion. Bone Healing and Fusion Concerns This is where the evidence becomes most consequential for workers' compensation claims involving spine and fracture surgery. Spine Surgery: A systematic review and meta-analysis published in the *North American Spine Society Journal (December 2025) pooled data from 13 retrospective cohort studies and found that GLP-1 RA use was associated with a **reduced risk of pseudarthrosis** (failure of bone fusion), with no consistent increase in infection, wound healing complications, cerebrospinal fluid leak, or thromboembolic events. However, the authors cautioned that heterogeneity across studies was notable and causality cannot be inferred. Contradicting these pooled findings, a [study on posterior cervical spine surgery published in *The Spine Journal (September 2025) found that patients on GLP-1 medications had a 4.79 times higher risk of non-union and a 2.12 times higher risk of dysphagia compared to controls. The discrepancy likely reflects differences in surgical approach, patient nutrition status, and GLP-1 exposure timing. Lower Extremity Fractures: A large retrospective cohort study with two-year follow-up found that perioperative GLP-1 RA use was associated with a modestly higher risk of nonunion following lower extremity fracture fixation, though without increased wound complications. Importantly, GLP-1 use was linked to reduced cardiac arrest and one-year mortality — suggesting that the systemic cardiovascular benefits may outweigh the localized bone healing concern for many patients. Joint Replacement: Results are mixed. For total shoulder arthroplasty, patients on GLP-1 RAs showed no increase in length of stay or complications. For total knee arthroplasty, semaglutide was associated with decreased periprosthetic joint infection, sepsis, and readmissions — but also with increased acute kidney injury, pneumonia, myocardial infarction, and hypoglycemic events. Total hip arthroplasty data showed similar infection and readmission benefits without the same medical complication increase. Nutritional and Muscle Mass Implications Rapid weight loss from GLP-1 medications — often 10–15% of body mass over 6 to 12 months — can deplete lean muscle along with fat, particularly in patients over 60 or those not performing resistance training. This sarcopenic effect directly undermines postoperative rehabilitation. Muscle mass and function are essential for ambulation after joint replacement and spine surgery, and insufficient protein intake increases the risk of delayed wound healing and infection. For workers' compensation cases, this creates a practical question: is the injured worker's nutritional status adequate to support surgical healing? Providers should document total weight loss, duration of GLP-1 use, and whether the patient is supplementing with protein or creatine. Practical Takeaways for Workers' Compensation Stakeholders - - Treating physicians and QMEs should document GLP-1 medication use, duration, total weight loss, and nutritional supplementation in every surgical evaluation for an injured worker. - - Utilization review organizations should flag GLP-1 use when evaluating requests for spine fusion, fracture fixation, or joint replacement — and ensure preoperative nutrition optimization is addressed in the treatment plan. - - Claims administrators should be aware that GLP-1-related complications (non-union, revision surgery, aspiration events) may extend claim duration and costs, but that the medications also reduce systemic risks like infection and mortality. - - The standard hold period** before elective surgery remains debated: the ASA recommends 7 days for weekly formulations, while AAOS research suggests 14 days may be safer. Surgeons and anesthesiologists should coordinate on a case-by-case basis ...

IHSS (In-Home Supportive Services) is a California program providing in-home care to eligible aged, blind, or disabled individuals, primarily funded by the state with federal matching. Fraud typically involves providers claiming hours not worked, recipients overstating needs, collusion between providers and recipients, identity theft, or billing for unprovided services. Common charges include grand theft, false claims, and welfare fraud under California Penal Code sections. The California Department of Social Services (CDSS) tracks program integrity through annual reports. Fraud complaints and investigations occur, but criminal prosecutions and convictions represent a small fraction of cases, as many are resolved administratively (e.g., overpayment recovery, service reductions, or terminations). Provider fraud accounts for the vast majority (~80-83%) of investigated cases. Recent news (as of 2026) shows ongoing but limited high-profile IHSS-specific convictions reported publicly; one 2026 LA County DA case involved an IHSS caregiver convicted after surveillance showed physical capabilities contradicting claimed needs. The Special Investigative Unit of RJN Investigations, Inc. was recently notified by the Los Angeles County District Attorney’s Office of their successful prosecution in the case of People of The State of California v M. Lopez based upon a documented fraud referral. In this case, the claimant was employed as a caretaker of the California Department of Social Services – I.H.S.S. At the time of the claimant’s deposition, he appeared wearing a back support and ambulating with the aid of a cane. Proactively, the Senior Claims Examiner authorized the RJN SIU Department to perform RUSH surveillance. During the ongoing surveillance, extensive video evidence was obtained depicting the claimant ambulating freely without any noticeable signs of artificial support or noticeable restrictions. The video evidence was subsequently provided to the QME for review and comment. In his QME report, it stated in part the following: “Overall, review of the subrosa video footage demonstrates a degree of inconsistency between what Mr. Lopez reported and exhibited at the time of the PQME examination, and what he was visualized performing during the video segments…My reporting on this case has changed as a result of this additional information and my revised reporting follows below…” In compliance with the regulations set forth by the California Department of Insurance Fraud Division, the RJN SIU formally filed this case with their office as well as with the Los Angeles County District Attorney’s Office. Felony charges were then issued against the claimant, and a preliminary criminal hearing was set. The claimant failed to appear for the hearing and as a result, a felony bench warrant was issued for his arrest. The claimant subsequently had formal interactions with law enforcement and their check of NCIC revealed his felony warrant where he was promptly arrested. After several criminal hearings, the claimant entered into a plea bargain agreement entailing formal probation and having to pay restitution in the amount of $ 43,263.00 ...

Following alarming reports that California officials failed to properly safeguard federal funds, House Committee on Oversight and Government Reform Committee Chairman James Comer (R-Ky.) and Oversight Committee Republicans launched an investigation into rampant taxpayer fraud in California’s hospice programs. In a letter to California Governor Gavin Newsom, the lawmakers emphasized that the Newsom administration has been aware of state audit reports of hospice fraud for at least four years but has failed to prevent or detect it and has enabled hospice providers to defraud the American taxpayer and exploit vulnerable patients. The Oversight Committee is now requesting documents and communications regarding California’s oversight and internal controls to detect and prevent fraud for its federally funded hospice programs. “Recent reporting has revealed alarming evidence of fraudulent activity in California’s hospice programs, including agencies overbilling Medicare and fraudulently enrolling beneficiaries without their knowledge. In California, your administration’s Departments of Public Health, Social Services and Health Care Services all have a role in overseeing federally funded hospice programs. The Committee is concerned your administration does not have sufficient internal controls to prevent and detect fraud and is not conducting proper oversight of these hospice programs. As a result, Americans across the country are paying for California’s rampant hospice fraud and vulnerable patients are being exploited. California has a well-documented history of fraud in its hospice programs. Your administration has been aware of credible reports of hospice fraud for at least four years. Despite these red flags, it appears California has enabled hospice providers to defraud the American taxpayer and exploit vulnerable patients,” wrote the Republican lawmakers. The Committee’s investigation into Minnesota’s federally funded social service programs exposed widespread failures by state agencies to conduct oversight and prevent fraud, with similar schemes now appearing in California’s hospice programs. According to a March 29, 2022, report from the California State Auditor, Los Angeles County has seen a 1,500 percent increase in hospice providers since 2010, with providers overbilling Medicare by at least $105 million in a single year. In addition, a whistleblower reported that California has minimal safeguards to prevent fraudsters from obtaining hospice licenses, including allowing individuals living abroad to secure them, and described schemes in which fraudsters recruit seniors. The Centers for Medicare and Medicaid Services recently estimated that Los Angeles County alonerepresents $3.5 billion in hospice fraud, and that 18 percent of all hospice billing in the United States comes from this single county. “Last year, California Attorney General Rob Bonta called hospice fraud in California, specifically in Los Angeles County, ‘an epidemic.’ The March 2022 audit report highlighted several red flags and key warning signs of fraud: many providers are listed at the same address; very low patient counts compared with the rest of the State; patients listed as terminally ill were later discharged alive; excessive billing for services that may not have been provided; and staff were shared across multiple hospice providers. The Committee is requesting documents and communications regarding California’s oversight and internal controls to detect and prevent fraud for its federally funded hospice programs,” continued the Republican lawmakers ...

Kara Sandler worked for Modernizing Medicine, Inc. (ModMed), a Delaware corporation. Her employment contract required that any employment-related disputes be resolved through binding arbitration under the Federal Arbitration Act, following the procedures of the California Arbitration Act. The contract further specified that arbitration would be administered by JAMS (Judicial Arbitration & Mediation Services, Inc.), whose rules provide that an arbitrator — not a court — must decide threshold questions about the validity and enforceability of the arbitration agreement itself. The contract also contained a generic severability clause stating that if "a court or other body of competent jurisdiction" found any provision invalid, the offending provision would be enforced to the maximum extent permissible and the remainder of the agreement would survive. Sandler filed suit against ModMed in the Southern District of California, asserting state and federal claims of age and disability discrimination. ModMed moved to compel arbitration. Sandler opposed the motion, arguing the arbitration agreement was unconscionable. The district court denied ModMed's motion. While it acknowledged that the incorporation of JAMS rules constituted a delegation of validity questions to the arbitrator, the court relied on several California state-court decisions to conclude that the severability clause undermined that delegation. The court's reasoning was that because the severability clause referenced "a court," the parties may not have clearly intended for an arbitrator to be the one deciding whether the arbitration agreement was enforceable. Having claimed authority to decide the question itself, the district court then ruled the arbitration agreement unconscionable and refused to sever the offending provisions. The Ninth Circuit reversed. The panel in the published case of Sandler v. Modernizing Medicine, Inc. No. 24-6623 (March 2026) and took issue with the district court's reliance on California state-court opinions, and held that the district court misapplied federal law and should never have reached the unconscionability question at all. The court began with settled precedent: when parties incorporate JAMS (or AAA) rules into an arbitration agreement, that incorporation constitutes "clear and unmistakable" evidence of an intent to delegate questions of arbitrability to the arbitrator. The panel cited Patrick v. Running Warehouse, LLC, 93 F.4th 468, 481 (9th Cir. 2024), and Brennan v. Opus Bank, 796 F.3d 1125, 1130 (9th Cir. 2015), as controlling authority on that point. The central question was whether a generic severability clause mentioning "a court" introduced enough ambiguity to negate that otherwise clear delegation. The Ninth Circuit held it did not. The panel reasoned that the two clauses can coexist: the delegation clause sends disputes — including validity disputes — to the arbitrator, while the severability clause merely provides a contingency mechanism if a court were to interpret the contract for any reason. The court emphasized the "cardinal principle of contract construction" from Mastrobuono v. Shearson Lehman Hutton, Inc., 514 U.S. 52, 63 (1995), that contract clauses should be read as consistent with one another rather than in conflict. Letting the severability clause swallow the delegation clause would render the latter superfluous, a result disfavored under Trident Center v. Connecticut General Life Insurance Co., 847 F.2d 564, 566 (9th Cir. 1988). The panel also took issue with the district court's reliance on California state-court opinions. Whether parties clearly and unmistakably intended to delegate arbitrability is a question of federal law under the FAA, as established in Brennan, 796 F.3d at 1129, and First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938, 944 (1995). Any state rule that uses a severability clause to negate an otherwise clear delegation would be preempted by the FAA, under the reasoning of Kindred Nursing Centers Limited Partnership v. Clark, 581 U.S. 246, 251 (2017), and AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 339 (2011). The Fifth and Sixth Circuits have reached the same conclusion. See Arnold v. Homeaway, Inc., 890 F.3d 546, 552 (5th Cir. 2018); Blanton v. Domino's Pizza Franchising LLC, 962 F.3d 842, 846–47 (6th Cir. 2020). The Ninth Circuit vacated the unconscionability ruling, reversed the denial of the motion to compel, and remanded with instructions to grant the motion and stay the case pending arbitration ...

Sutter Medical Center, Sacramento, and Sutter Fairfield Surgery Center have agreed to pay $3.2 million to resolve allegations that they failed to effectively guard against theft and diversion of controlled substances, U.S. Attorney Eric Grant announced. This settlement relates to allegations of the entities’ collective commission of at least 628 violations of recordkeeping and security requirements under the Controlled Substances Act (CSA). The United States contends that these two Sutter-affiliated entities violated the CSA by, among other violations, failing to: notify the Drug Enforcement Administration (DEA) of theft or loss, keep accurate records of controlled substances, complete biennial inventories, maintain complete controlled substance order records, and provide effective controls against diversion. The investigation was initiated following the death of a pediatric anesthesiologist. “We remain steadfast in our commitment to hold health care providers accountable for failing to effectively guard against the diversion of potentially dangerous controlled substances,” said U.S. Attorney Grant. “Our community deserves the right to place its trust in health care providers that dispense controlled substances and to know that they adhere to and apply the right safeguards to ensure safety around those products.” “DEA registrants play a critical role in protecting the public and that responsibility starts with strict compliance to the Code of Federal Regulations,” said DEA Special Agent in Charge, Bob P. Beris of the San Francisco Field Division. “If a company chooses to ignore these obligations, it puts communities at risk and undermines the safeguards designed to keep the public safe. DEA holds registrants accountable and in turn, expects them to keep the public safe.” The DEA conducted the investigation. Assistant U.S. Attorney David Thiess assisted in completing the resolution on behalf of the United States. The claims resolved by this settlement are allegations only, and there has been no determination of liability ...

Hyewon Pechkis and Joseph Pechkis, a married couple, were tenured physics professors at California State University, Chico (Chico State). Hyewon alleged she was subjected to harassment and discrimination by the department chair based on his perceived bias against women and Hyewon's Korean ancestry and national origin. The chair allegedly confronted Hyewon aggressively enough to cause her to fear for her physical safety, and she was eventually diagnosed with chronic post-traumatic stress disorder, major depressive disorder, and generalized anxiety disorder stemming from the hostile working environment. The couple raised their concerns with the dean of the College of Natural Sciences, but Chico State took no action to address the chair's behavior. With no relief forthcoming, the Pechkises accepted employment offers at California Polytechnic State University (Cal Poly), 400 miles away, effectively giving up their tenured positions at Chico State. Shortly after they announced their planned departure, Chico State Vice Provost Mahalley Allen emailed Hyewon claiming the university had "serious concerns" about a potential Family Educational Rights and Privacy Act (FERPA) violation related to old blog postings Hyewon had written in Korean, which the complaint alleged were based on inaccurate translations. The complaint further alleged that Allen contacted Cal Poly to inform them of the unresolved FERPA investigation in what plaintiffs characterized as an attempt to sabotage their transfer. A Chico State dean also allegedly caused unnecessary delays in transferring plaintiffs' lab equipment to Cal Poly. Despite these efforts, Cal Poly continued to extend employment offers to both professors. In December 2024, the Pechkises filed suit against the Trustees of the California State University asserting six causes of action: discrimination, retaliation under the California Fair Employment and Housing Act (Gov. Code, § 12900 et seq.), failure to engage in the interactive process, hostile working environment, failure to prevent discrimination and harassment, and whistleblower retaliation. In March 2025, defendant filed an anti-SLAPP motion under Code of Civil Procedure section 425.16 seeking to strike the second cause of action (FEHA retaliation) and the sixth cause of action (whistleblower retaliation). The Butte County Superior Court denied the motion. The court found that defendant had satisfied the first prong of the anti-SLAPP analysis — that the challenged claims arose from protected activity — because the FERPA investigation constituted an "official proceeding authorized by law." However, the court then found that plaintiffs demonstrated a likelihood of success on the merits, concluding that their discrimination complaints were protected activity and that Chico State's constructive discharge of their tenured employment qualified as an adverse employment action. Defendant appealed. The Third District affirmed the denial but on different grounds than the trial court in the published case of Pechkis v. Trustees of the California State University, No. C103742 (March 2026),holding that defendant failed to carry its burden on the first prong of the anti-SLAPP analysis in the first place. The court applied the framework established in Bonni v. St. Joseph Health System (2021) 11 Cal.5th 995, 1009, which requires a defendant bringing an anti-SLAPP motion to "identify what acts each challenged claim rests on and to show how those acts are protected under a statutorily defined category of protected activity" through a claim-by-claim elemental analysis. The court found that defendant had instead employed the kind of broad "gravamen" approach that the Supreme Court disapproved of in Bonni — essentially arguing that because the retaliation causes of action were based "in part" on communications between Chico State employees and Cal Poly, both causes of action should be stricken in their entirety. Citing Park v. Nazari (2023) 93 Cal.App.5th 1099, 1108–1109, the court held that when a defendant seeks to strike entire causes of action without identifying specific claims within them that rest on protected activity, the defendant fails to carry its first-step burden so long as the causes of action contain at least one claim that does not arise from protected conduct. The court identified several allegations of potentially unprotected conduct underlying the challenged causes of action that defendant never addressed. Both causes of action alleged retaliation through constructive discharge — an adverse employment action that courts have recognized as unprotected activity. The court noted that defendant itself effectively conceded constructive discharge was central to these causes of action by making it the sole focus of its second-prong argument, yet defendant never explained how constructive discharge constituted protected activity under the first prong. Similarly, the causes of action alleged retaliation through the initiation of a sham FERPA investigation, and the court observed that under Laker v. Board of Trustees of California State University (2019) 32 Cal.App.5th 745, 773, claims based on the fact of an investigation or its outcome — as opposed to investigation-related speech — are not subject to the anti-SLAPP statute. The court also rejected defendant's assumption that because the FERPA investigation qualified as an "official proceeding authorized by law," all acts associated with it were shielded by anti-SLAPP protection. The statute protects only "written or oral statement[s]" made in connection with such proceedings, not every act undertaken within them. Quoting the Supreme Court's warning in Park v. Board of Trustees of California State University (2017) 2 Cal.5th 1057, 1067, the court cautioned that conflating discriminatory decisions with investigation-related speech in the anti-SLAPP analysis could render the statute "fatal for most harassment, discrimination and retaliation actions against public employers." The court acknowledged that individual allegations within the two causes of action might still be protected conduct susceptible to a more targeted anti-SLAPP motion but declined to perform that analysis on defendant's behalf, concluding that defendant had "wholly failed to 'propose where to make the incisions.' " ...

A woman from the Larchmont area of Los Angeles was sentenced to 35 months in federal prison for defrauding Medicare out of more than $14 million by submitting fraudulent claims for hospice care and diagnostic testing services that were either unnecessary or not provided at all. Sophia Shaklian, 38, was sentenced by United States District Judge Stanley Blumenfeld Jr., who also ordered her to pay $14,103,043 in restitution. Shaklian pleaded guilty in November 2025 to one count of health care fraud. From March 2019 to August 2024, Shaklian and her co-schemers – often using aliases – used multiple bogus hospice and diagnostic testing providers enrolled with Medicare and submitted fraudulent claims on behalf of companies she owned. These businesses included a Shaklian-owned hospice company – the Pasadena-based Chateau d’Lumina Hospice and Palliative Care – and several diagnostic testing companies: Saint Gorge Radiology in Sylmar; Hope Diagnostics in North Hollywood; Direct Imaging & Diagnostics and Lab One – both based in Hollywood; and Labtech and Lifescan Diagnostics in Claremont. Shaklian and her co-schemers used the information of Medicare beneficiaries, and checked beneficiaries’ Medicare eligibility to knowingly and willfully submit fraudulent claims to Medicare on behalf of beneficiaries who did not need the services, had never received the services, and were not familiar with the fraudulent hospice and diagnostic testing providers, with the intent to defraud Medicare into reimbursing the sham providers for those claimed services. For example, Shaklian and her co-schemers knowingly and willfully submitted a false and fraudulent claim for $2,000 in November 2022 to Medicare for diagnostic testing purportedly provided to an individual. Shaklian admitted in her plea agreement that fraudulent claims were submitted on behalf of the sham providers, some by herself and others by her co-schemers during and in furtherance of the above scheme. Because Shaklian was involved in the billing and was familiar with the amounts Medicare paid to the fraudulent providers on the types of claims submitted during this scheme, she caused a loss of at least $14,103,043 to Medicare. Co-defendant Alex Alexsanian, 48, a.k.a. “Samvel” and “Samo,” of Burbank, pleaded guilty on January 20 to one count of conspiracy to launder monetary instruments. He will face a statutory maximum sentence of 20 years in federal prison at his April 28 sentencing hearing. The United States Department of Health and Human Services Office of the Inspector General and the FBI are investigating this matter. Assistant United States Attorney Kevin B. Reidy of the Major Frauds Section is prosecuting this case ...

Jessica Garcia worked for The Merchant of Tennis, Inc. (Merchant), a California corporation operating in San Bernardino County, from July through December 2019. In May 2022, she filed a third amended consolidated class action complaint on behalf of herself and other employees, alleging various wage-and-hour violations under the California Labor Code and other federal and state employment laws. While Garcia's motion for class certification was pending in 2024, Merchant pulled approximately 954 current and former employees into mandatory meetings with management and asked them to sign individual settlement agreements releasing their wage and hour claims in exchange for cash payments averaging roughly $918 each — over $875,000 in total. Garcia had not signed an agreement, but the vast majority of putative class members had. In November 2024, Garcia moved to invalidate the settlements, arguing Merchant obtained them through fraud and coercion. The trial court found that Merchant had made "false and misleading" representations to secure the agreements: it gave workers unfounded claims about the low recovery rates in class actions, falsely stated that certain claims had been dismissed, described the releases as limited when they actually covered all claims, marked communications "confidential" to discourage sharing with class counsel, and misleadingly suggested that arbitration agreements barred participation in the lawsuit without disclosing that only 40 percent of workers had such agreements. The court concluded the 954 individual settlement agreements were voidable and ordered a curative notice giving workers 45 days to revoke their agreements and join the class action. The parties then fought over what the curative notice should say about repayment. Merchant wanted the notice to warn workers that if they revoked their settlements and Merchant ultimately prevailed, they could be required to return the money. Garcia argued that including such language would discourage low-wage workers from joining the suit and that any repayment issue could be addressed later through an offset against recovery. The San Bernardino County Superior Court sided with Garcia. Finding no binding California authority on point, the court followed two federal cases — Marino v. CACafe, Inc. (N.D. Cal. Apr. 28, 2017) 2017 WL 1540717 and McClellan v. Midwest Machining, Inc. (6th Cir. 2018) 900 F.3d 297 — and ruled that the curative notice would inform workers they would not be required to return any payment, though the amount received might be treated as an offset against any future recovery. The court rejected Merchant's argument that California's rescission statutes (Civ. Code, §§ 1689, 1691) required immediate repayment, calling that position "simplistic legal analysis" that ignored the complexity of the employer-employee relationship and the court's duty to prevent abuses undermining the administration of justice. The court stayed its order to allow Merchant to seek appellate review. The Court of Appeal granted Merchant's petition for writ of mandate in a 2–1 decision, directing the trial court to vacate its February 28, 2025 order and reconsider the curative notice in the published case of The Merchant of Tennis, Inc. v. Superior Court No. E085766 (March 2026). The majority (Acting Presiding Justice Miller, joined by Justice Codrington) held that California's rescission statutes govern the situation and require the curative notice to inform workers that repayment of settlement funds may be required at the conclusion of litigation. The court acknowledged that under Civil Code section 1693, repayment need not be immediate and can be delayed until judgment without substantial prejudice to the other party. But the majority concluded that neither section 1692 nor section 1693 authorizes a trial court to forgive repayment entirely at the outset of litigation. The court read section 1692 — which permits a court to "in its judgment adjust the equities between the parties" — as contemplating equitable adjustments at the time of final judgment, not at the beginning of a case. The majority found the federal authorities relied on by the trial court unpersuasive, noting that Marino provided no analysis of California rescission law, and McClellan addressed a narrow exception for federal Title VII and Equal Pay Act claims brought by an individual plaintiff, not a California wage-and-hour class action. However, the court stopped short of requiring immediate repayment, holding that the curative notice should inform class members that if they choose to rescind, they could be responsible for repayment at the conclusion of litigation under Civil Code sections 1689, 1691, and 1693, while the trial court retains discretion to adjust equities under section 1692 at the time of judgment. Justice Raphael dissented, arguing that the majority's reading of the rescission statutes was too rigid and that section 1692 grants trial courts broad equitable authority to fashion remedies — including excusing repayment — at any stage of a proceeding, not only at final judgment ...

For decades, Body Mass Index has been the go-to shorthand for obesity in surgical planning. But anyone who has reviewed a lumbar fusion file knows the frustration: BMI treats a 260-pound powerlifter and a 260-pound sedentary claimant as identical risks. As Orthopedics This Week put it, BMI is “about as precise as estimating blood loss by ‘eyeballing the suction canister.’” Now, a new tool is aiming to change that calculus. The Lumbar Subcutaneous Adipose Classification (LSAC) is an MRI-based system that goes beyond simply weighing a patient or calculating a ratio. Rather than producing a single number, the LSAC maps the distribution of subcutaneous fat across the lumbar surgical corridor. According to the OTW report, the system doesn’t just measure fat—it classifies its pattern in a way that turns out to be a powerful predictor of post-operative infections and other complications following lumbar interbody fusion. The LSAC is the latest evolution in a line of research that has steadily chipped away at BMI’s dominance. In 2018, Shaw and colleagues published their Subcutaneous Lumbar Spine (SLS) Index, which measured the ratio of subcutaneous adipose depth to spinous process height at the surgical site using preoperative MRI. Studying 285 patients who underwent laminectomy or lumbar fusion, the team found that the SLS Index was significantly associated with total complications, perioperative complications, and the need for revision surgery—outperforming both BMI and raw fat depth measurements alone. Then came the Spine Adipose Index (SAI), published in The Spine Journal in 2021. A multicenter case-control study of posterior instrumented lumbar fusion patients found that the SAI was more sensitive than either BMI or subcutaneous fat thickness in predicting deep surgical site infections, and it demonstrated excellent inter-observer reliability—meaning different radiologists reading the same MRI would reach the same conclusion. A 2024 study in Global Spine Journal further validated the approach, finding that the Subcutaneous Lumbar Spine Index (SLSI) was a superior predictor of early surgical site infection after transforaminal lumbar interbody fusion across a cohort of over 3,600 patients. The researchers noted that each millimeter increase in subcutaneous fat thickness corresponded to roughly a six percent increase in infection odds—but that accounting for the spinous process height relationship made the prediction even stronger. Where the SLS Index and SAI each produced a single numerical ratio, the LSAC takes the concept further by generating a classification of adipose distribution pattern across the lumbar corridor. Think of the difference between taking a patient’s temperature (one data point) versus mapping the inflammation across an entire joint (a diagnostic picture). The LSAC leverages data already sitting in every preoperative lumbar MRI—no additional imaging, no extra cost—and converts it into an actionable risk category. This matters for the workers’ compensation world because the research base is now clear: site-specific fat distribution is a far better predictor of lumbar surgical complications than BMI. A recent meta-analysis pooling data from seven studies confirmed that localized adiposity measures showed stronger associations with post-operative infection than BMI in spinal fusion procedures. For the Workers' Compensation Industry, this development touches several pressure points. First, preoperative risk stratification: carriers and utilization review teams may soon have a tool that more precisely identifies which claimants face elevated surgical risks—well before the scalpel touches skin. That creates opportunities for prehabilitation protocols, targeted weight-management programs, or frank conversations about risk-benefit tradeoffs that go beyond a generic BMI threshold. Second, causation disputes. When a post-fusion infection develops, the question of whether the infection was a foreseeable surgical complication versus an independent intervening cause is already a common battleground. A preoperative LSAC classification showing high-risk adipose distribution could strengthen the argument that the complication was predictable—and perhaps even that authorization should have required additional safeguards. Third, the “obesity defense” gets more nuanced. Defense counsel have long pointed to BMI as a comorbidity that contributed to poor outcomes. But the LSAC’s ability to differentiate between patients at the same BMI—one with favorable fat distribution, one without—could undercut blanket arguments and demand more granular expert testimony on both sides of the aisle. The LSAC doesn’t replace clinical judgment. No classification system does. But what it does is extract meaningful, reproducible risk information from imaging that is already being ordered in virtually every lumbar fusion case. For an industry that spends billions annually on spinal surgery claims, a better way to identify which patients are heading toward complications—before they get there—is the kind of incremental advance that compounds over thousands of files ...

Kathleen Charles, a dementia patient who was otherwise in good health, was admitted to the memory care wing of WellQuest Elk Grove, a residential care facility in Sacramento County. Her family informed staff that Kathleen was a "wanderer" who needed monitoring, and WellQuest's own service plan noted she required frequent supervision. Three days after admission, Kathleen was found sitting unattended in an outdoor courtyard in direct sunlight on a day when the temperature reached 102 degrees. She had burns covering roughly a quarter of her body and an internal temperature of about 105 degrees. She fell into a coma and died four days later. When Kathleen was admitted, her niece Erika Wright - acting under a durable power of attorney for Kathleen's health care - signed an arbitration agreement on Kathleen's behalf. The agreement provided that "any and all claims or disputes arising from or related to this Agreement or to your rights, obligations, care, or services at WellQuest of Elk Grove shall be resolved by submission to neutral, binding arbitration in accordance with the Federal Arbitration Act." It also contained a delegation clause stating that "an arbitrator will decide any question about whether a claim or dispute must be arbitrated." The agreement designated JAMS as the arbitration administrator but did not reference any specific JAMS rules or provide a link to them. Eight months after Kathleen's death, her family filed suit. On Kathleen's behalf (as survivor claims), plaintiffs alleged elder neglect, negligence, fraud, and a criminal elder abuse tort. Her brother Raymond, niece Erika, and nephew Thomas also brought individual claims for wrongful death and negligent infliction of emotional distress. WellQuest moved to stay proceedings and compel arbitration. The Superior Court Judge denied the motion on multiple grounds. First, the court found that the delegation clause did not "clearly and unmistakably" assign threshold arbitrability questions - including enforceability and unconscionability - to the arbitrator, so the court resolved those issues itself. Second, the court determined that the arbitration agreement was not unconscionable. Third, it held that Raymond, Erika, and Thomas were not parties to the agreement, so their individual wrongful death and emotional distress claims were not arbitrable. Finally, turning to Kathleen's survivor claims, the court exercised its discretion under Code of Civil Procedure section 1281.2, subdivision (c), and declined to compel arbitration, finding that if those claims went to arbitration while the family's individual claims proceeded in court, there was a risk of conflicting rulings on common factual and legal issues. The court also rejected WellQuest's argument that the FAA's procedural provisions governed the agreement, concluding that the phrase "in accordance with the Federal Arbitration Act" did not expressly incorporate the FAA's procedural rules. The Third District affirmed the trial court on all issues in the published case of Wright v. WellQuest Elk Grove -C105070 (March 2026) On the delegation clause, the court held that the language - providing that "an arbitrator will decide any question about whether a claim or dispute must be arbitrated" - fell short of the "clear and unmistakable" standard required to delegate threshold arbitrability issues away from the court. The court contrasted the agreement with the provision upheld in Aanderud v. Superior Court (2017) 13 Cal.App.5th 880, 892, where the clause explicitly covered "the interpretation, validity, or enforceability" of the agreement and incorporated specific JAMS rules that expressly assigned arbitrability to the arbitrator. Here, the clause said nothing about enforceability, unconscionability, or interpretation of the agreement itself, and the JAMS reference included no link to or copy of the applicable rules. Drawing on the reasoning in Ajamian v. CantorCO2e, L.P. (2012) 203 Cal.App.4th 771, 783, the court explained that when delegation language is susceptible to multiple reasonable interpretations — one covering only substantive disputes and the other reaching threshold enforceability questions — the ambiguity cannot satisfy the heightened "clear and unmistakable" standard. On the FAA preemption issue, the court held that the phrase "in accordance with the Federal Arbitration Act" did not expressly designate the FAA's procedural provisions as controlling. Relying on the California Supreme Court's holdings in Cronus Investments, Inc. v. Concierge Services (2005) 35 Cal.4th 376, Cable Connection, Inc v. DIRECTV, Inc. (2008) 44 Cal.4th 1334, and most recently Quach v. California Commerce Club, Inc. (2024) 16 Cal.5th 562, 582, the court reaffirmed that the California Arbitration Act's procedural rules - including section 1281.2, subdivision (c) - apply by default in state court proceedings, and parties must use express language to opt out of them in favor of the FAA's procedural framework. The court acknowledged the contrary result in Rodriguez v. American Technologies, Inc. (2006) 136 Cal.App.4th 1110, where the phrase "pursuant to the FAA" was found sufficient, but disagreed with that reasoning, finding it inconsistent with the principle that a departure from the default CAA framework requires more exacting language. Following Valencia v. Smyth (2010) 185 Cal.App.4th 153, 177, the court concluded the agreement implicitly incorporated the CAA's procedural provisions, leaving the trial court free to apply section 1281.2, subdivision (c), to keep all claims together and avoid conflicting rulings. Because these two holdings disposed of the appeal, the court did not reach the parties' remaining arguments regarding unconscionability or whether Raymond's statutory right to trial preference would independently override arbitration ...

United States Attorney Craig H. Missakian announced criminal charges against an individual for perpetrating a large-scale fraud targeting federal health care funds distributed through the Medicare Advantage program. Anar Rustamov, a national of Azerbaijan who appears to have entered the United States illegally, was indicted by a federal grand jury and charged with health care fraud for a scheme involving thousands of false claims for medical equipment totaling more than $90 million. According to the indictment, Rustamov, 38, formerly of Sunnyvale, California and a national of Azerbaijan, was part of a scheme to submit thousands of fraudulent claims to Medicare Advantage Organizations (“MAOs”) on behalf of unsuspecting beneficiaries for medical equipment such as blood glucose monitors and orthotic braces. The indictment alleges that Rustamov, from October 2024 through June 2025, executed a scheme through an entity Rustamov created, Dublin Helping Hand, to submit large volumes of claims to MAOs offering Medicare Part C benefit plans. The indictment alleges the scheme sought reimbursement of more than $90 million for medical equipment that was not provided, not needed by patients, and not authorized by a medical provider. The listed patients were unaware that Rustamov and others were submitting the claims, and the referring medical provider listed on the submissions did not authorize the claims, according to the indictment. The defendant is at large. Rustamov remains at large (a fugitive). No arrests have been reported, and authorities are seeking him. This appears to be a standalone case based on available public information, with no named co-conspirators or additional arrests announced as of March 23, 2026. Details come primarily from the official DOJ press release and contemporaneous reporting; no public court docket or full indictment text is yet widely available beyond these summaries. United States Attorney Craig H. Missakian added that when “the Administration declared a War on Fraud, it meant to target exactly this kind of conduct. Rustamov participated in a scheme to steal nearly $100 million in taxpayer funds from a program intended to help those who truly need medical care.” The case is being prosecuted by Assistant U.S. Attorney Maya Karwande with the assistance of Lynette Dixon. The prosecution is the result of an investigation by the U.S. Department of Health and Human Services Office of Inspector General and the Federal Bureau of Investigation ...

On April 29, 2024, the EEOC published its Enforcement Guidance on Harassment in the Workplace - the first update to the agency's harassment guidance since 1999. The guidance replaced five prior guidance documents issued between 1987 and 1999 and was approved by a partisan 3-2 vote. The guidance was a sweeping, roughly 90-page document that addressed harassment across every protected characteristic under federal EEO law. The next year, on January 28, 2025, EEOC Acting Chair Andrea Lucas rolled back much of the EEOC's Biden-era guidance related to gender identity discrimination and harassment, aligning with President Trump's Executive Order 14168 signed on Inauguration Day. However, Lucas could not formally rescind guidance that had been previously approved by a majority vote of the Commission, and she was limited to removing certain materials from the EEOC's internal and external websites and other public documents. At that time, the EEOC lacked a quorum, so a formal rescission vote was not possible. Along the way, the State of Texas and the Heritage Foundation sued to enjoin the guidance, arguing it was contrary to law, arbitrary and capricious, and in excess of the EEOC's statutory rulemaking authority. In the case of Texas v. Equal Employment Opportunity Commission, No. 2:24-CV-173 (N.D. Tex. May 15, 2025) a federal district court in Texas agreed, and struck down portions of the 2024 guidance addressing bathroom, dress, and pronoun accommodations, finding the EEOC had exceeded its statutory authority by expanding the definition of "sex" beyond the biological binary. Following up on the announced Andrea Lucas roll back, on January 22, 2026, the EEOC officially voted 2-1 along party lines to formally rescind its 2024 Enforcement Guidance on Harassment in the Workplace in its entirety. Chair Lucas and Commissioner Brittany Panuccio (confirmed in October 2025, restoring the quorum) voted for rescission, while Democratic Commissioner Kalpana Kotagal dissented. It had been anticipated that the EEOC might limit the rescission to portions addressing sexual orientation and transgender status, but the Commission voted to rescind the guidance in its entirety - including sections on race, color, pregnancy, disability, and other protected categories that were largely uncontroversial. Some employment law commentators have theorized that the Trump EEOC chose a complete rescission because it would be easier than making piecemeal edits, and that any replacement guidance might emphasize religious-based harassment and so-called "reverse" harassment. The rescission does not amend Title VII itself or overturn existing Supreme Court precedent, including the Bostock v. Clayton County, Georgia, 590 U.S. 644 (2020) decision holding that Title VII prohibits discrimination based on sexual orientation and gender identity. The guidance was nonbinding and provided stakeholders with information on how the EEOC planned to enforce the law - it did not change employers' underlying legal obligations. Employees can still pursue harassment claims, courts interpret the law independently, and state and local anti-discrimination laws remain unaffected. California's primary anti-discrimination and anti-harassment statute is the Fair Employment and Housing Act (FEHA), codified at Government Code § 12900 et seq. FEHA is one of the most expansive employment civil rights laws in the nation, and it operates entirely independently of the EEOC's guidance. The EEOC's rescission does not alter any California employer's obligations under FEHA. FEHA does not rely on judicial interpretation to extend protections to gender identity and sexual orientation - they are expressly listed in the statute. California law prohibits workplace discrimination and harassment based on gender identity, gender expression, sexual orientation, marital status, sex/gender (including pregnancy, childbirth, breastfeeding and related medical conditions), reproductive health decisionmaking, race (including traits associated with race, such as hair texture and hairstyle), religion (including religious dress and grooming practices), national origin, age, disability, medical condition, genetic information, military or veteran status, and other protected characteristics. The consensus among employment law practitioners is that while the federal enforcement landscape has shifted significantly, employers should not treat the rescission as a green light to relax their anti-harassment programs. The rescission has prompted federal lawmakers to introduce legislation - such as the BE HEARD Act of 2026 - that would amend Title VII to expressly include sexual orientation, gender identity, sex stereotypes, sex characteristics, and pregnancy in the definition of sex. In practical terms, employment lawyers advising California employers are counseling them to maintain their existing anti-harassment policies, training programs, and complaint procedures without any weakening in response to the EEOC's action - because California law independently requires everything the EEOC guidance recommended and more ...

On March 3, 2026, a San Francisco company called RecovryAI announced that the FDA has granted Breakthrough Device Designation to its AI-powered "Virtual Care Assistants" - software designed to guide patients through recovery after joint replacement surgery. The announcement, which coincided with the company's emergence from more than two years of stealth development, signals a potentially significant shift in how post-operative orthopedic care is delivered and documented. The product works like this: after a total knee or hip replacement, the surgeon prescribes the Virtual Care Assistant to the patient. During the first 30 days of recovery at home, the AI checks in with the patient twice daily about sleep, activity levels, diet, pain, and other recovery milestones. It provides guidance drawn from established clinical protocols. When it detects that a patient's recovery is deviating from expected patterns - signs of possible infection, blood clot, wound complications, or functional decline - it escalates to the care team with the relevant clinical context. The FDA's Breakthrough Device Designation is reserved for technologies that address serious conditions and show potential to meaningfully improve existing standards of care. The designation does not mean the product is approved - it means the FDA has agreed to provide the company with earlier and more frequent regulatory engagement as it moves toward authorization. RecovryAI is pursuing clearance under a Class II pathway for patient-facing Software as a Medical Device, and is currently running a multi-site pivotal study at locations including OrthoArizona, one of the nation's largest orthopedic practices, and Mercy Medical Center in Baltimore. If ultimately authorized, the FDA's decision would create an entirely new device classification for patient-facing AI systems in clinical care. The timing is significant. More than 80 percent of surgical procedures in the United States are now performed on an outpatient basis, meaning patients are sent home during the critical early window when most post-surgical complications develop. Joint replacement patients - many of them workers' compensation claimants recovering from workplace injuries - are increasingly navigating that early recovery period without daily clinical oversight. The traditional model of a follow-up visit at two weeks or four weeks leaves a substantial gap that this technology is designed to fill. Why this matters: If this class of technology gains FDA authorization and enters clinical practice, it will generate a continuous, timestamped record of a patient's post-surgical recovery - what the patient reported about their pain, activity, and symptoms, and what guidance they received, twice a day for 30 days. That is a data trail that did not previously exist in most cases ...

Jazmin Ayala-Ventura worked as a janitor for CCS Facility Services–Fresno Inc., a commercial janitorial company, from June 2021 to March 2022. When she was hired, CCS emailed her links to an online onboarding system where she reviewed and electronically signed several company policies, including a five-page "Mutual Agreement to Arbitrate." The system required employees to scroll through each document before they could click "yes" to agree, and offered the option to view the agreement in English or Spanish. The agreement covered "all claims, disputes, and/or controversies … whether or not arising out of Employee's employment or the termination of employment," contained a class action waiver, survived termination of employment, and could only be revoked by a writing signed by both the employee and a CCS human resources representative. CCS agreed to bear all arbitration costs except each party's own legal fees. In August 2024, Ayala-Ventura filed a putative class action against CCS alleging a battery of wage-and-hour violations under the California Labor Code - including unpaid wages, missed meal and rest breaks, failure to reimburse expenses, and unfair business practices under Business and Professions Code section 17200. CCS moved to compel individual arbitration and dismiss the class claims. Ayala-Ventura opposed, arguing the agreement was both procedurally and substantively unconscionable - specifically that its scope was overbroad, it lacked mutuality, and it was indefinite in duration. She relied heavily on Cook v. University of Southern California (2024) 102 Cal.App.5th 312, a Second District opinion that struck down a similar-looking arbitration agreement with USC. The Fresno County Superior Court granted CCS's motion. The court found procedural unconscionability was minimal, distinguished Cook on the facts, and concluded the agreement was not substantively unconscionable. It ordered arbitration of Ayala-Ventura's individual claims, dismissed the class claims, and stayed the case pending arbitration. Because an order compelling arbitration is generally not directly appealable, the Fifth District Court of Appeal treated the appeal as a petition for writ of mandate and denied the petition on the merits in the published case of Ayala-Ventura v. Superior Court --F089695 (March 2024). On procedural unconscionability, the court agreed with the trial court that the degree was minimal. The agreement was adhesive in form, and an employee might reasonably fear losing a job offer by declining it. But the agreement was a clearly labeled standalone document (not a buried clause), was available in two languages, used legible formatting, and there was no evidence of deception or time pressure. On substantive unconscionability, the court addressed each of Ayala-Ventura's arguments. First, on overbreadth, the court acknowledged the agreement's language could be read to reach claims unrelated to employment, but applied Civil Code section 1643 to construe the ambiguity in a way that rendered the agreement lawful - limiting it to employment-related claims. Even under Ayala-Ventura's broader reading, the court found the agreement distinguishable from Cook because CCS is a janitorial services company, not a sprawling university with hospitals and stadiums, making the prospect of wide-ranging non-employment claims far less realistic. Second, on duration, the court found that the agreement's survival clause was not unconscionable in context, again because CCS's limited operations made the concern about perpetual exposure largely speculative. Third, on mutuality, the court found the agreement sufficiently bilateral: unlike the Cook agreement, CCS's version expressly bound the company's related entities and limited claims against employees and agents to acts taken in their capacity as such. Both employer and employee were subject to arbitration on equivalent terms. Finally, the court addressed stare decisis. It clarified that all published Court of Appeal decisions bind all superior courts statewide - the trial court was wrong to suggest Cook was not binding simply because the Fifth District had not yet cited it. However, the court confirmed that trial courts may fairly distinguish binding precedent on the facts, and the Fifth District itself found Cook factually distinguishable for the reasons discussed above ...

Federal Prosecutors announced that a criminal complaint was unsealed charging Karl Czekai, 29, of Carmichael, with making interstate threats against the Judge presiding over his domestic case with his wife. According to court documents, Czekai is separated from his wife, who moved to Oklahoma with their child to get away from him. Once in Oklahoma, Czekai’s wife filed for a protective order against Czekai, alleging that Czekai has held guns up to her and threatened to shoot her multiple times. Also, according to court documents, in February 2026, Czekai began making social media posts about his wife and the Oklahoma judge who granted the protective order and is presiding over related proceedings. These posts include: - - Images of Czekai’s avatar pointing a gun at a sitting judge with “FAMILY COURT” signage on the bench; - - Text threatening the judge that she will no longer be safe: “Hello, judge [VICTIM 1] of the Oklahoma City Courthouse remember me...the comfort of your title, the security of your robe, the certainty of your authority - all of that is about to be tested”; - - Text warning that time is of the essence: “tick tock, Your Honor. You will be the first to set the example. I’m going to diss you publicly. to show future judges, and lawyers I’m not f---ing around”; - - Text advising that he carries a gun: “Updated the gun to something more of what I would carry. I only carry a .45 and I’m definitely a 1911 guy”; and - - Text suggesting he is ready to follow through: “This is the breaking point. This is him saying: enough is enough.” Additionally, and as detailed in court documents, Czekai posted and shared with his wife videos threatening graphic violence against her. If convicted, Czekai faces a maximum statutory penalty of five years in prison. Any sentence, however, would be determined at the discretion of the court after consideration of any applicable statutory factors and the federal Sentencing Guidelines, which take into account a number of variables. The charges are only allegations; the defendant is presumed innocent until and unless proven guilty beyond a reasonable doubt. The Federal Bureau of Investigation is conducting the investigation with assistance from the Midwest City Police Department and the Oklahoma County Sheriff’s Office. Assistant U.S. Attorney Elliot Wong is prosecuting the case ...

Epic Systems Corporation is a major American health information technology company. It develops electronic health records (EHR) software - the systems hospitals and clinics use to store and manage patient medical records. They are the dominant EHR vendor in the United States. Over 1,900 hospitals and 49,000 clinics use Epic's EHR software. Their Care Everywhere interoperability tool exchanges over 20 million patient records daily. On January 13, 2026, Epic Systems Corporation and four healthcare system co-plaintiffs (OCHIN, Reid Health, Trinity Health, and UMass Memorial Health) filed a landmark lawsuit in the Central District of California targeting an alleged syndicate of companies that fraudulently extracted hundreds of thousands of patient medical records from national health data exchange networks - not to treat patients, but to allegedly sell those records to mass tort law firms. The defendants allegedly gained access to the Carequality and TEFCA interoperability frameworks - systems that collectively facilitate over one billion patient record exchanges monthly - by falsely claiming to be healthcare providers retrieving records for treatment purposes. In reality, according to the complaint, the records were being harvested and sold to plaintiff attorneys for use in identifying and recruiting clients for mass tort lawsuits, including PFAS “forever chemical” litigation and other class actions. No law firms are named as defendants - the complaint stops at the companies allegdly selling records to attorneys (LlamaLab, Hoppr, NHPC), not the firms buying them. However, the complaint is unusually detailed about the commercial relationship: LlamaLab advertised at Mass Torts Made Perfect, Hoppr pitched personal injury attorneys directly, and the Integritort predecessor was caught on video demonstrating live record retrieval to a "law firm lead generation business." The complaint is unusually explicit about the role of plaintiff-side attorneys as the downstream buyers of these records. Key details include: - - LlamaLab, Inc. (New York): Described in the complaint as offering “Same-Day Medical Records Retrieval for Law Firms” and “medical-grade AI analysis tools.” LlamaLab sponsored the October 2025 Mass Torts Made Perfect conference, a major national plaintiff attorney gathering, and exhibited in the medical records category. Its CEO, Shere Saidon, presented its services to class action attorneys at that conference. - - Hoppr, LLC (Dallas, TX): Founded by Meredith Manak, also the CEO of defendant Unit 387 LLC. Hoppr’s stated business is to “instantly aggregate all patient records” for law firms and insurance companies. Manak gave a September 2025 presentation to personal injury attorneys titled “How to Request and Receive All of Your Client’s Medical Records In Less Than 48 Hours for 1 Low Flat Fee.” - - PFAS Litigation Targeting: Records returned by RavillaMed to healthcare providers contained no actual treatment information, but instead reorganized existing diagnoses to highlight PFAS (forever chemical) exposure associations — a subject heavily litigated in mass tort court. - - Nationwide Healthcare Provider Corp (NHPC): Defendant Ryan Hilton of the Mammoth entity group is listed as the NPI owner of NHPC, which markets patient record access directly to attorneys. NHPC’s promotional materials boasted it could pull records “straight from providers’ EHRs” to “representative firms” in “minutes, not weeks.” On March 13, 2026, plaintiffs and defendant Critical Care Nurse Consultants LLC d/b/a GuardDog Telehealth entered a Stipulated Judgment and Permanent Injunction, the first resolution in the case. Paragraph 5 of that document reads "GuardDog admits that, since it began operating as a company in 2024, its goal was to provide chronic care management (“CCM”) and remote patient monitoring (“RPM”) for patients, but that did not happen. For the duration of its existence, its business instead focused on requesting, reviewing, and summarizing medical records, and providing those medical records to law firms. GuardDog further admits that its predecessor, Critical Care Nurse Consulting LLC (“CCNC”), provided similar services and medical records to law firms between 2022 and 2024;" This lawsuit represents the first major litigation challenge to what plaintiffs characterize as an organized “Hydra” of entities exploiting health data infrastructure for plaintiff recruitment. Plaintiffs allege that "When caught, rather than stopping their activity, the bad entity owners, operators, and those in their inner circles simply create new companies. The scheme thus operates like a Hydra: when one fraudulent entity is exposed, the bad actors birth a new one. As an example, when concerns were raised to Health Gorilla about one of their connections, an entity called Critical Care Nurse Consulting, over its affiliation with law firms, it abruptly stopped taking patient records via Carequality in September 2024. That very same month, a related organization previously onboarded by Health Gorilla, Defendant SelfRx, began taking large volumes of patient records. Both Critical Care Nurse Consulting and SelfRx are customers of Defendant Unit 387, an intermediary health data broker onboarded by Health Gorilla." The case is ongoing. A scheduling conference is set for April 23, 2026, and several defendants (e.g., the Mammoth group) have filed or are briefing motions to dismiss ...

The Los Angeles Police Department’s Special Operations Division, Major Complaint Unit, arrested Police Officer III Peter Mastrocinque and Police Officer II Nicole Grant after the Los Angeles County District Attorney’s Office filed felony charges related to Unemployment Insurance fraud under California Penal Code Section 550(a)(5) and Insurance Code Section 2101(a). Mastrocinque was appointed to the Department on September 16, 2008, and Grant on October 31, 2016. Both officers are assigned to Newton Division and have been placed on administrative leave as part of this investigation. The investigation, led by the Special Operations Division Major Complaint Unit, responsible for investigating criminal misconduct by Department employees, including fraud, focused on Unemployment Insurance applications submitted by Mastrocinque and Grant during 2020 and 2021. The investigation followed a 2023 review by the Los Angeles County District Attorney’s Office of suspected Unemployment Insurance fraud involving applications submitted during the COVID-19 pandemic. This review raised concerns about applications associated with multiple individuals, including Mastrocinque and Grant, and was subsequently referred to the Los Angeles Police Department’s Special Operations Division for further investigation. Investigators working in partnership with the Los Angeles County District Attorney’s Justice System Integrity Division developed probable cause to believe Mastrocinque and Grant submitted fraudulent Unemployment Insurance applications and received payments to which they were not entitled. Both officers surrendered themselves, were booked, and later released. Nicole Grant was assigned Booking Number 7199424, and Peter Mastrocinque was assigned Booking Number 7199437. The arrests are part of a broader crackdown - in October 2025, the LA County District Attorney's Office charged 13 Los Angeles County employees from seven different agencies with felony grand theft for stealing a combined $437,383 in state unemployment benefits between 2020 and 2023. While working for LA County and receiving paychecks, the 13 defendants allegedly submitted fraudulent unemployment insurance claims to the California Employment Development Department, falsely claiming under penalty of perjury that they earned less than $600 per week. In fact, they earned more than $600 a week, making them ineligible for unemployment benefits. The agencies involved in the 13 cases spanned a wide cross-section of county government, including the Justice, Care and Opportunity Department, the Department of Public Social Services, and others - notably including employees whose very job was to help the public determine whether they were eligible for public benefits. By December 2025 there was a second wave of arrests. Eleven additional LA County employees were subsequently charged with felony grand theft, bringing the total to 24 employees accused of stealing a combined $741,518 in unemployment benefits between 2020 and 2023. Many of these individuals submitted more than 40 fraudulent income certifications - not only omitting their employment in their initial applications, but continuing to submit fraudulent income certifications every two weeks, claiming under penalty of perjury that they were unemployed even as they continued to receive biweekly paychecks from LA County. The arrests of LAPD Officers Mastrocinque and Grant in March 2026 are thus part of this continuing and expanding crackdown, which has now extended beyond general county employees to sworn law enforcement personnel. The cases are being prosecuted through the DA's Justice System Integrity Division, which specifically handles misconduct by public employees. The Los Angeles Police Department’s Special Operations Division Major Complaint Unit investigates unemployment insurance fraud, abuse of benefits, and other allegations of criminal misconduct involving Department personnel. The Unit is committed to aggressively investigating fraud and benefits abuse to ensure accountability, safeguard public resources, and uphold the integrity of the Department ...

Roy Payan and Portia Mason are blind individuals who enrolled as students at Los Angeles City College, a campus of the Los Angeles Community College District (LACCD), in 2015. Both registered with the college’s Office of Special Services and were approved for accommodations - including recorded lectures, preferential seating, access to electronic text materials, and test-taking accommodations - beginning in the Spring 2016 semester. Both students relied on JAWS screen-reading software to access electronic text. Despite their approved accommodations, Payan and Mason encountered pervasive accessibility barriers. Payan received textbook chapters only after they had already been covered in class. Classroom software platforms such as MyMathLab and Etudes were inaccessible, forcing Payan to complete homework through limited tutoring sessions rather than independently like his peers. Library databases, campus computers, and the LACCD and LACC websites were also inaccessible, hampering his ability to register for courses, apply for financial aid, or stay informed about campus life. Both students had difficulty securing test-taking accommodations, and their accommodation letters were provided only in inaccessible print format. Payan was also steered away from a single-semester math course and directed into a slower two-semester sequence because of his disability. The plaintiffs - joined by the National Federation of the Blind and its California chapter - sued LACCD under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act in March 2017. After the first trial in 2019, the jury awarded $40,000 to Payan and $0 to Mason. All parties appealed, and the Ninth Circuit vacated and remanded in Payan v. Los Angeles Community College District, 11 F.4th 729 (9th Cir. 2021). On retrial, the jury found LACCD liable on fourteen of nineteen factual allegations and determined that LACCD had intentionally violated Title II on nine of them. The jury awarded $218,500 plus attorney’s fees to Payan and $24,000 plus attorney’s fees to Mason. LACCD then moved for remittitur. Relying on the Supreme Court’s decision in Cummings v. Premier Rehab Keller, P.L.L.C., 596 U.S. 212 (2022) - which held that emotional distress damages are not recoverable under Spending Clause antidiscrimination statutes - the district court granted the motion and slashed the awards to $1,650 for Payan and $0 for Mason. The court reasoned that the jury’s verdicts could only be attributed to either emotional distress damages or lost educational opportunities, both of which the court deemed impermissible. The Ninth Circuit reversed and vacated the remittitur, remanding with instructions to reinstate the original jury awards of $218,500 to Payan and $24,000 to Mason in the published case of Payan v. Los Angeles Community College District, No. 24-1809 (9th Cir. Mar. 11, 2026) The panel addressed three issues. First, it found no forfeiture, concluding that LACCD was not barred from challenging emotional distress damages on remand because the issue had not been decided in the prior appeal. Second, the panel agreed with the district court that emotional distress damages are unavailable under Title II of the ADA. Although Title II was enacted under the Fourteenth Amendment and Commerce Clause rather than the Spending Clause, its statutory text defines its remedies as those of the Rehabilitation Act, which in turn incorporates Title VI’s remedial framework. Under Cummings, 596 U.S. at 221–22, and Barnes v. Gorman, 536 U.S. 181, 189–90 (2002), this chain of statutory incorporation means Title II’s remedies are coextensive with those available under contract-law principles - and emotional distress damages are generally not compensable in contract. Third - and critically - the panel held that the district court erred by failing to recognize that the jury’s award could reflect compensatory damages for lost educational opportunities, a form of relief that remains available after Cummings. Agreeing with the Eleventh Circuit’s reasoning in A.W. by & Through J.W. v. Coweta County School District, 110 F.4th 1309, 1315–16 (11th Cir. 2024), the court held that plaintiffs who prove intentional discrimination may recover compensation for the educational benefits they were denied. Because the trial evidence showed that Payan and Mason were effectively barred from meaningful participation in their courses, and because the jury instructions allowed compensation for “any injury” caused by LACCD’s violations, the jury’s award was consistent with the record. The district court abused its discretion by granting remittitur without considering this legally viable basis for the damages. Judge Lee dissented in part. He agreed that emotional distress damages are barred and that lost-opportunity damages remain available in theory, but he concluded that the plaintiffs failed to present sufficient concrete evidence of lost educational opportunities to justify awards exceeding $200,000. In his view, the testimony amounted to generalized descriptions of diminished educational experiences rather than quantifiable economic losses, and the district court’s remittitur should have been affirmed ...

President Donald Trump is set to sign an executive order to formally launch a task force to investigate fraud nationwide, led by Vice President JD Vance. Federal Trade Commission Chairman Andrew Ferguson will serve as vice chair of the Task Force to Eliminate Fraud, while White House aide Stephen Miller will serve as senior adviser. The executive order instructs the task force to develop a comprehensive national strategy against fraud impacting programs administered with state and local governments to provide housing, food, medical, and financial assistance. The order also calls for the development of anti-fraud standards such as proof of identity and other documentation requirements, as well as audits. The order will highlight fraud in Minnesota, among other states. Last year, YouTuber Nick Shirley went viral for filming seemingly vacant daycare centers in Minnesota. The National Desk The Minnesota case has already led to dozens of indictments, including for phony nutrition and autism care programs. Earlier this year, the administration also established a new DOJ division for national fraud enforcement, designed to enforce federal criminal and civil laws against fraud targeting federal government programs, federally funded benefits, businesses, nonprofits, and private citizens nationwide. And locally, Los Angeles County District Attorney Nathan J. Hochman announced the launch of a countywide LA Metro bus advertisement campaign warning everyone that lying or misrepresenting facts to obtain workers’ compensation benefits to which a person is not entitled is a felony. “Knowingly making a false statement to collect workers’ compensation benefits is textbook fraud, and we are filing charges against anyone who engages in it - employees, medical providers, attorneys or any other participants in the schemes,” District Attorney Hochman said. “If you choose to falsify a claim, exaggerate an injury, or create false medical documentation, you are committing a felony, and my office will prosecute you. In fact, the very buses that soon will carry this message are connected to a recent case in which a Metro bus driver is now charged with staging a fake workplace fall to fraudulently obtain benefits.” District Attorney Hochman added: “The goal of workers’ compensation is to protect legitimately injured workers and provide necessary medical care and wage replacement. Fraud diverts resources, increases costs for employers and taxpayers, and undermines public trust in the system.” “Medical professionals play a critical gatekeeping role in the workers’ compensation system,” District Attorney Hochman stated. “Issuing disability notes without proper evaluation or without assessing whether modified duty is appropriate can perpetuate fraud. Knowingly creating or corroborating false documentation is criminal conduct.” Fraud schemes may also involve “capping,” an illegal practice in which attorneys or medical providers pay for client referrals. Kickbacks and referral payments tied to workers’ compensation claims are unlawful and will be prosecuted. Further, it is illegal for businesses to operate without providing workers’ compensation insurance coverage as required by law. While announcing the Office’s campaign, District Attorney Hochman thanked the Healthcare Fraud Division for its work in developing the campaign, particularly Assistant Head Deputy District Attorney Natalie Adomian for her leadership in bringing the initiative to fruition ...