Implicit Lies Can Be Health Care Fraud Crime, Third Circuit Says

Oct. 21, 2025, 4:05 PM UTC

A New Jersey man accused of defrauding an unnamed pharmacy benefit management company will face criminal health-care fraud charges after a federal appeals court Tuesday reversed an order dismissing the indictment.

In reviving the charges, the US Court of Appeals for the Third Circuit joined the Fifth and Eleventh Circuits in recognizing that implicit misrepresentations can give rise to valid criminal health-care fraud charges.

Federal prosecutors charged Carmine Mattia Jr. with one count of conspiracy to commit healthcare fraud, three counts of substantive healthcare fraud, witness tampering, and obstruction.

Mattia was employed by a telecommunications company that contracted with the ...

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