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UNITED STATES OF AMERICA ex rel. KATHI HOLLOWAY,
Relator-Appellant,
v.
HEARTLAND HOSPICE, INC.,
Defendant,

HEARTLAND HOSPICE SERVICES, LLC; HCR MANORCARE, INC.; HCR HOME HEALTH CARE & HOSPICE, LLC; MANORCARE HEALTH SERVICES, LLC,
Defendants-Appellees.
   No. 19-3646
Appeal from the United States District Court
for the Northern District of Ohio at Toledo.
No. 3:10-cv-01875—James G. Carr, District Judge.
Decided and Filed: June 3, 2020
Before: MERRITT, MOORE, and MURPHY, Circuit Judges.


_________________________
OPINION
_________________________

KAREN NELSON MOORE, Circuit Judge. The qui tam provisions of the False Claims Act (“FCA”) encourage whistleblowers to act as private attorneys general and sue companies making false claims for federal money. See 31 U.S.C. §§ 3729–3733. Kathi Holloway, the qui tam relator in this action, sued Heartland Hospice and related entities (“Heartland”) under the FCA for orchestrating a corporate-wide scheme to submit false claims for payments from Medicare and Medicaid to cover hospice care. Heartland allegedly enrolled patients in hospice when they were not terminally ill and kept them there, even when employees like Holloway urged their release.

Heartland, however, shoots back that Holloway is not a genuine whistleblower, that her claims are drawn from prior allegations against Heartland, and accordingly that her qui tam action is prohibited by the FCA’s public-disclosure bar. In the alternative, Heartland argues that Holloway has not satisfied the FCA’s heightened pleading standard for allegations of fraud and, in particular, that she has not satisfied the limited exception to that standard that we announced in U.S. ex rel. Prather v. Brookdale Senior Living Cmtys., Inc., 838 F.3d 750 (6th Cir. 2016). We hold that Holloway’s action is barred in light of prior public disclosures. We accordingly AFFIRM the district court’s judgment of dismissal.



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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
DEMETRIUS EUGENE WOODSON,
Defendant-Appellant.
   No. 19-1906
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:19-cr-00002-1—Paul Lewis Maloney, District Judge.
Decided and Filed: June 3, 2020
Before: GRIFFIN, THAPAR, and READLER, Circuit Judges.


_________________________
OPINION
_________________________

CHAD A. READLER, Circuit Judge. The target of Demetrius Woodson’s interstate diamond-stealing scheme, it seems, could only be Jared. Woodson and his accomplices stole nearly $100,000 in diamonds from over a dozen Jared jewelry stores in six states. Following Woodson’s guilty plea to charges of conspiring to commit offenses against the United States, the district court applied a two-level sentencing enhancement after finding that a central part of Woodson’s scheme was perpetual relocation to avoid law enforcement. See U.S.S.G. § 2B1.1(b)(10)(A). On appeal, Woodson argues that his practice of returning to his “home base” in Toledo means he never “relocated” the scheme, for Guidelines purposes. We reject his argument and AFFIRM the judgment of the district court.



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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
ALEX ALBERTO CASTRO (19-1166); DANTE ANDRE HOWARD (19-1292); SOLON TATUM (19-1422),
Defendants-Appellants.
   Nos. 19-1166/1292/1422
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:17-cr-00193-1—Robert J. Jonker, District Judge.
Argued: May 5, 2020
Decided and Filed: June 3, 2020
Before: MERRITT, SUHRHEINRICH, and SUTTON, Circuit Judges.


_________________________
OPINION
_________________________

A jury convicted Defendants-Appellants Alex Castro, Dante Howard, and Solon Tatum of conspiring to distribute heroin, cocaine, and marijuana in western Michigan. The evidence at trial depicted a sophisticated drug trafficking organization, with the conspirators going to great lengths to avoid detection. Appellants challenge the tools the government used to ensnare members of the organization, including wiretaps that recorded drug-related conversations between co-conspirators. Because the district court properly authorized those wiretaps, properly admitted evidence obtained from them, properly concluded that the evidence offered by the government supported Appellants’ convictions, and properly sentenced Appellants, we affirm.