United States v. Robinson
263 F. Supp. 3d 248
| D.D.C. | 2017Background
- Defendant Ivan L. Robinson, a clinician, is charged with 61 counts of unlawful distribution of oxycodone (prescribing outside the usual course of professional practice and not for a legitimate medical purpose) and two money‑laundering counts.
- The government seeks to call former patients to testify about their addiction histories, detoxification/rehabilitation, and observations about drug activity around Robinson’s clinics.
- Robinson moved in limine to preclude testimony about (1) patients’ addiction/detox/rehab history and (2) observations of unlawful drug activity around his practice, invoking FRE 401 and 403.
- The court previously excluded lay testimony regarding patient overdoses or deaths after receiving prescriptions, because of high unfair‑prejudice and speculative causation concerns.
- The government proffers that patient addiction and subsequent detox/rehab are probative of the appropriateness of prescribing and of witness credibility; government concedes testimony about non‑oxycodone drug activity outside the office is generally inadmissible but may seek to offer evidence of immediate resale/distribution of pills obtained from the defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of patient testimony that they were addicted to oxycodone when treated | Addiction testimony is relevant to whether prescriptions were in the usual course of practice and to witness credibility | Such testimony is prejudicial and should be excluded under FRE 401/403 | Allowed: patients may testify they were addicted; relevant to propriety of prescribing and credibility |
| Admissibility of patient testimony about subsequent detoxification/rehabilitation | Rehab/detox shows current sobriety, supports credibility and probative value | Prejudicial or irrelevant to defendant’s prescribing conduct | Allowed: testimony about detox/rehab admissible; probative of credibility and not substantially outweighed by prejudice |
| Testimony about patient overdoses or deaths after receiving prescriptions | Gov’t argued such events explain why opioids are regulated | Defense argued high prejudice and speculative causation | Excluded: testimony about deaths/overdoses after prescriptions barred because unfairly prejudicial and low probative value |
| Testimony about unlawful drug activity observed around defendant’s clinic (including resale/distribution) | Gov’t may show what patients did with pills (e.g., immediate resale) to prove misuse/diversion | Defense seeks to exclude observations of outside illegal activity as irrelevant and prejudicial | Preliminary exclusion: court precludes testimony about illegal activity around the office on present record; gov’t must approach court before offering such evidence at trial |
Key Cases Cited
- None with official reporter citations cited in the opinion (court relied on Federal Rules of Evidence and prior in‑camera/motion rulings).