Case Explained: 26a0175p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-16 The Sixth Circuit affirmed the conviction and sentence of Samuel Harris for violating the Anti-Kickback Statute and related healthcare fraud conspiracy charges. The court held that the district court did not abuse its discretion in denying Harris’s request for a jury instruction on the advice-of-counsel defense because Harris failed to fully disclose pertinent facts to his attorney, specifically omitting that he paid employees on a per-patient basis rather than a flat salary as assumed in the legal advice. The court further ruled that the district court did not abuse its discretion in denying a motion for a mistrial following an improper prosecutorial remark about the identity of Harris’s counsel, finding under the standard of review that the isolated comment was unlikely to mislead the jury given the prompt limiting instruction and the strength of the evidence against Harris. Additionally, the court affirmed the evidentiary ruling excluding portions of a recorded meeting as inadmissible hearsay, noting that the defendant failed to renew his request for admission of the full tape after agreeing to submit only specific clips. As a result, Harris’s conviction stands and he remains subject to his 30-month sentence. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.