United States v. Anthony King
898 F.3d 797
| 8th Cir. | 2018Background
- Artex Medical Clinic (later KJ Medical) operated as a cash "pill mill" in Little Rock: walk-in patients paid for evaluations and frequently received hydrocodone and alprazolam (Xanax) prescriptions, often via pre-signed physician prescriptions.
- Kristen Raines, an APRN, worked at Artex (July–Sept 2014) and KJ (Nov 2014–Jan 2015) and was the only licensed prescriber on site for controlled substances during much of that time.
- Anthony King recruited patients across Arkansas to the clinics; both were charged in a conspiracy to distribute controlled substances without effective prescriptions; King pled guilty, Raines was tried.
- At trial the government introduced PMP summary charts, patient files, cooperating witnesses, a confidential informant’s testimony and video, and expert testimony from Dr. Carlos Roman about pain-management standards and red flags.
- The jury convicted Raines of conspiracy (acquitted on two substantive distribution counts); the district court attributed large pill quantities to Raines, applied an abuse-of-trust enhancement, and sentenced her to 70 months; King received 120 months after an upward variance.
Issues
| Issue | Raines' Argument | Government's Argument | Held |
|---|---|---|---|
| Admissibility of PMP summary evidence | PMP summaries were unreliable and unfairly prejudicial | Summaries corroborated by sign-in logs and hardcopy prescriptions; admissible and not unfairly prejudicial | Admitted; district court did not abuse discretion under Rule 403 and summaries were corroborated |
| Expert testimony (Dr. Roman) | Expert lacked personal knowledge and insufficient record review to opine | Dr. Roman was qualified; his experience and review rendered opinions helpful and reliable under Rule 702 | Admitted; no abuse of discretion—testimony assisted jury despite limits on definitive statements |
| Jury instructions: good-faith vs. willful blindness | Requested instruction misstated law by making standard subjective; sought a good-faith instruction emphasizing defendant’s sincere belief | Willful blindness instruction appropriate because defendant denied knowledge despite strong contrary evidence | Court properly refused Raines' proposed good-faith instruction and gave willful-blindness instruction; instructions as a whole adequate |
| Sufficiency of evidence & sentencing (drug-quantity; abuse-of-trust; substantive reasonableness) | Insufficient evidence that Raines joined conspiracy or knew purpose; challenged drug-quantity, abuse-of-trust enhancement, and sentence reasonableness | Ample circumstantial and corroborative evidence of knowledge and tacit participation; quantities attributable as foreseeable scope of conspiracy; enhancement and within-Guidelines sentence proper | Conviction upheld; district court did not clearly err on quantity or trust enhancement; sentences substantively reasonable for both defendants |
Key Cases Cited
- Davis v. White, 858 F.3d 1155 (8th Cir. 2017) (Rule 403 deference to district court)
- Quigley v. Winter, 598 F.3d 938 (8th Cir. 2010) (reversal standard for evidentiary rulings)
- United States v. Darden, 70 F.3d 1507 (8th Cir. 1995) (broad discretion in conspiracy trials on admissibility)
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) (expert reliability and experience may support admissibility)
- United States v. Smith, 573 F.3d 639 (8th Cir. 2009) (standard for ‘‘usual course of professional practice’’ in medical-prescribing cases)
- United States v. Moore, 423 U.S. 122 (1975) (rejecting purely subjective good-faith standard for medical narcotics defense)
- Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review of sentencing decisions)