In U.S. v. Shelburne, Chief Judge Jones of the W.D. Va. struck several of the counts of which Dr. Shelburne was convicted earlier at trial, in a case related to "a scheme to defraud Medicaid by submitting bills for services that were not performed, were paid for by others, or were not medically necessary."
Part of the opinion involves the application of the recent Supreme Court decision regarding what are the "proceeds" of illegal activity for purposes of money laundering, in United States v. Santos.
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