Case Explained: FinalOpinion in case# 24-2236

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-06 The Seventh Circuit affirmed the convictions of Rishi Shah and Shradha Agarwal for mail, wire, bank fraud, and money laundering related to a multi-million-dollar fraud scheme at Outcome Health. The court rejected the defendants’ challenges regarding pretrial asset restraints, grand jury testimony, evidentiary rulings, and jury instructions. Regarding the Sixth Amendment claim that an overbroad pretrial protective order violated their right to counsel of choice by freezing assets needed to pay their preferred attorneys (Quinn Emanuel and McGuireWoods), the court held that the defendants forfeited this challenge by failing to object at trial despite having sufficient information to identify the over-restraint years earlier. Under the plain error standard, the burden remained on the defendants to prove that the improperly restrained “Other Assets” were liquid enough to have been sold in time to afford their counsel of choice. The court found no clear error in the district court’s determination that these assets were illiquid and could not have been liquidated for the required $7.8 million within the relevant timeframe, particularly given market conditions and transfer restrictions. Regarding the Fifth Amendment due process claim that an FBI accountant knowingly made false statements to the grand jury regarding asset traceability, the court affirmed the district court’s finding that the government did not act with knowledge of the error. The over-restraint resulted from a disconnect between the drafting attorney and the tracing expert rather than willful misconduct. Furthermore, even if an error occurred, it was harmless because the defendants failed to show that the grand jury misstatement affected their substantial rights or the trial’s outcome. On evidentiary grounds, the court found no abuse of discretion in admitting prior consistent statements under Federal Rule of Evidence 801(d)(1)(B) to rehabilitate cooperating witnesses, noting that any potential over-admission was harmless given the overwhelming evidence of guilt and the witnesses’ poor credibility on cross-examination. Finally, the court rejected the claim that jury instructions allowed for invalid theories of fraud, ruling that the instructions correctly stated the law regarding fraudulent inducement and breach-of-contract defenses, and that any error in this regard was not plain or prejudicial. The practical consequence is that Shah and Agarwal’s convictions and sentences stand; Shah remains subject to a 90-month prison term and forfeiture order, while Agarwal remains subject to her sentence and forfeiture order. The case is closed with no remand for new trial or modification of the asset restraints. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.