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Appeals court upholds Medicaid fraud charges

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A woman charged with defrauding Indiana’s Medicaid program of nearly $350,000 lost the appeal of her partial motion to dismiss the charges.

Medea Woods filed an interlocutory appeal from a Jefferson Circuit Court ruling, claiming that some of her alleged crimes fell outside the five-year statute of limitations; that the state failed to provide sufficient facts in the charging information to allege the concealment exception; and that the crimes do not constitute a continuing wrong.

A federal grand jury in November 2009 indicted Woods, a clinical psychologist, with health care fraud for claims submitted between 2002 and 2007 after investigators noted an unusual number of bills submitted. Those charges were dismissed in July 2010, and the state filed charges in February 2011.

In Medea Woods v. State of Indiana, 39A05-1204-CR-189, the appeals court addressed only the issue of whether the information and probable cause was sufficient to allow the application of the concealment standard.

“The State must only allege sufficient facts in the charging information that the charged crimes were committed within the statute of limitations. However, we disagree with Reeves v. State, 938 N.E.2d 10, 15-16 (Ind. Ct. App. 2010), reh’g denied, trans. denied, and hold that the probable-cause affidavit can be considered in addition to the charging information to determine whether the State has alleged sufficient facts to place the charged crimes within the statute of limitations,” Judge Nancy Vaidik wrote for the panel. “We find that the State has alleged sufficient facts when the charging information and probable-cause affidavit are considered together and therefore affirm.”

“We find that when viewing the charging information and probable-cause affidavit together, the State has sufficiently alleged concealment to put Woods on notice that the State will argue that theory at trial,” Vaidik wrote. “Proving concealment and therefore that the crimes charged fell within the applicable statute of limitations are questions that the State has the burden of proving at trial, not at this point of the proceedings.”

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  1. It is amazing how selectively courts can read cases and how two very similar factpatterns can result in quite different renderings. I cited this very same argument in Brown v. Bowman, lost. I guess it is panel, panel, panel when one is on appeal. Sad thing is, I had Sykes. Same argument, she went the opposite. Her Rooker-Feldman jurisprudence is now decidedly unintelligible.

  2. November, 2014, I was charged with OWI/Endangering a person. I was not given a Breathalyzer test and the arresting officer did not believe that alcohol was in any way involved. I was self-overmedicated with prescription medications. I was taken to local hospital for blood draw to be sent to State Tox Lab. My attorney gave me a cookie-cutter plea which amounts to an ALCOHOL-related charge. Totally unacceptable!! HOW can I get my TOX report from the state lab???

  3. My mother got temporary guardianship of my children in 2012. my husband and I got divorced 2015 the judge ordered me to have full custody of all my children. Does this mean the temporary guardianship is over? I'm confused because my divorce papers say I have custody and he gets visits and i get to claim the kids every year on my taxes. So just wondered since I have in black and white that I have custody if I can go get my kids from my moms and not go to jail?

  4. Someone off their meds? C'mon John, it is called the politics of Empire. Get with the program, will ya? How can we build one world under secularist ideals without breaking a few eggs? Of course, once it is fully built, is the American public who will feel the deadly grip of the velvet glove. One cannot lay down with dogs without getting fleas. The cup of wrath is nearly full, John Smith, nearly full. Oops, there I go, almost sounding as alarmist as Smith. Guess he and I both need to listen to this again: https://www.youtube.com/watch?v=CRnQ65J02XA

  5. Charles Rice was one of the greatest of the so-called great generation in America. I was privileged to count him among my mentors. He stood firm for Christ and Christ's Church in the Spirit of Thomas More, always quick to be a good servant of the King, but always God's first. I had Rice come speak to 700 in Fort Wayne as Obama took office. Rice was concerned that this rise of aggressive secularism and militant Islam were dual threats to Christendom,er, please forgive, I meant to say "Western Civilization". RIP Charlie. You are safe at home.

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