U.S. v. Armenta

Record contained sufficient evidence to support defendant’s conviction on health care fraud, even though none of govt.’s witnesses identified defendant in court as culprit of said fraud. In-court identification of defendant is not required if defendant’s identity as culprit can be inferred from evidence admitted into record, and said evidence was sufficient to establish defendant’s identity as culprit, where: (1) defendant had same name as person who was indicted; (2) witnesses testified about their familiarity with “Angela Armenta,” and no one suggested that person they were talking about was not in courtroom; and (3) defendant stipulated to information contained in her resume that indicated that she worked for company at issue in instant prosecution, and that she worked in same position as individual who perpetrated fraud. Moreover, defendant’s counsel did not present any argument to jury that might have caused it to question his client’s identity as charged defendant. Also, Dist. Ct. could base imposition of obstruction of justice enhancement on defendant’s alteration of patient files during Medicare audit of defendant’s company.