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Eleventh Circuit Applies Newly Decided Supreme Court Identity Theft Conviction Standard

United States v. Gladden

By Maddison T. Booth

In United States v. Gladden, ten employees of Global Compounding Pharmacy were tried and convicted in the Northern District of Alabama on charges relating to a company-wide scheme to commit insurance fraud. A jury found Jessica Linton, manager of one of the company’s billing departments, and John Gladden, a district manager, guilty of: healthcare fraud; mail fraud; aggravated identity theft; conspiracy to commit healthcare fraud; and conspiracy to commit mail fraud. They both received prison sentences and were ordered to pay restitution and forfeiture. 


The court also reviewed the defendants’ aggravated identity theft convictions under a new interpretation of 18 U.S.C. § 1028A, which, at the time of the defendants’ trials, had not yet been set out by the Supreme Court. 


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