United States v. Halstead’s Empirical Analysis
634 F.3d 270 · 2011
Citation profile
10 federal appellate ·
Appellate journey
Relationships
Applies 18 U.S.C. § 1347 (§ 242 of the Health Insurance Portability and Accountability Act of 1996) · 18 U.S.C. § 1955 · 18 U.S.C. § 1956 (§ 1352 of the Money Laundering Control Act of 1986) · 18 U.S.C. § 371 · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on United States v. Booker · Gregg v. Georgia · Marks v. United States · Schriro Director Arizona Department of Corrections v. Summerlin · Book Named 'John Cleland's Memoirs of Woman of Pleasure' v. Attorney General of Commonwealth of Massachusetts
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e read Santos to hold that when a merger problem arises in the context of money laundering and illegal gambling, the required solution is to define the proceeds of the illegal gambling business as its net profits. When, however, a merger problem arises in the context of money laundering and an illegal activity other than illegal gambling, because of Justice Stevens’ opinion that would require addressing that situation on a case-by-case approach, we will leave further development of a solution to a future case that presents the problem.”
2 later decisions quote this exact passage · from the concurrence“[a]n individual cannot be convicted of money laundering for paying the essential expenses of operating the underlying crime.”
2 later decisions quote this exact passage · from the concurrence“After Priority One fraudulently obtained money from the healthcare providers, Halstead directed that the money be transferred from Priority One to West Virginia Medical Corporation, a company created to manage Priority One. He also directed that the money be further transferred from West Virginia Medical Corporation to Burns and himself, in this case through his company, Practice Systems. These transfers constituted the “transactions” of money laundering.... Halstead conducted a financial transaction with money he knew was the result of healthcare fraud, and he had the intent to further an unlawful activity when making those transfers, one category of transfers from Priority One to West Virginia Medical Corporation and another from West Virginia Medical Corporation to his own corporation’s bank accounts. Moreover, both the transfers to the management company and the transfers to Halstead’s company were separate from the transactions constituting healthcare fraud. The healthcare fraud charges were defined by the obtaining of money from the fraudulent billing of healthcare providers, while the money laundering charge was defined by transferring the proceeds thereafter. Thus, the merger problem never arises in the circumstances of this ease, and Santos provides Halstead no relief.”
1 later decision quote this exact passage · from the concurrence
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.