U.S. v. Maclin

In prosecution on Medicaid theft charges arising out of defendant’s embezzlement of funds from medical practice, where defendant transferred via computer Medicaid reimbursements from physician’s business account to defendant’s personal account, Dist. Ct. did not err in denying defendant’s motion for mistrial after prospective juror stated during voir dire that physician had “home for autism,” even though Dist. Ct. had previously granted defendant’s motion to preclude govt. from drawing attention to fact that physician had adult child with severe autism. Prospective juror’s statement did not implicate defendant’s guilt and was not inflammatory or material to any issue in case. Dist. Ct. also did not err in finding that physician was financially and technologically unsophisticated so as to support vulnerable victim enhancement, and any error in imposing said enhancement was harmless, where Dist. Ct. indicated that it would impose same sentence regardless of said enhancement.