Insurance Fraud is a Violent Crime

August 4, 2026

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Murder of Witness to Staged Auto Accident is Inadmissible in Fraud Case

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In United States Of America v. Ryan Harris, et al., Criminal Action No. 24-105, United States District Court, E.D. Louisiana (July 23, 2026) the defendants were charged in connection with an alleged staged-automobile-collision insurance fraud scheme in the New Orleans area and later crimes arising from the murder of cooperating witness Cornelius Garrison.

The Government sought to introduce evidence of Sean Alfortish’s 2011 fraud conviction and disbarment, Leon Parker’s 2010 arrest for a 2005 murder and arson, and Parker’s alleged physical abuse of Ryan Harris’ mother. The Government argued the evidence was intrinsic because it explained the structure of the alleged conspiracies and the relationships among the participants.

LAW:

Federal Rule of Evidence 404(b) generally bars other-act evidence offered to prove propensity but allows such evidence for non-character purposes if admissible. Intrinsic evidence is not governed by Rule 404(b) and may be admitted when it is inextricably intertwined with the charged offense, part of the same criminal episode, or a necessary preliminary step to the charged crime.

Federal Rule of Evidence 404(a)(1) prohibits the use of evidence “of any other crime, wrong, or act to prove a person’s character in order to show that on a particular occasion the person acted in accordance with the character.

DISCUSSION/ANALYSIS:

The Court rejected the Government’s argument that Alfortish’s prior fraud conviction was intrinsic merely because it affected how defense attorneys reacted to his involvement in staged-collision litigation.

The Court held that Alfortish’s disbarment was intrinsic because it explained why he allegedly funneled staged-accident clients to Vanessa Motta rather than litigating the cases himself, thereby illuminating the structure of the mail-and-wire-fraud conspiracy.

The district court reasoned that the prior acts tended to establish, among other things:

why a co-conspirator was hired to murder Womack and became a member of the conspiracy;
why it was feasible that, with that co-conspirator as the hit-man, Womack would be murdered;
the nature of the conspirator’s relationship with defendants; and
how the conspiracy came about.

As such, the district court concluded that the prior acts were inextricably intertwined with the crimes charged and served to complete the story of why the defendants would work together

CONCLUSION:

The Court ruled that evidence of Alfortish’s 2011 conviction and Parker’s 2010 arrest for a 2005 murder and arson is not admissible at trial.

Evidence of Alfortish’s disbarment and evidence that Parker physically abused Ryan Harris’ mother are admissible as intrinsic evidence, subject to appropriate limiting instructions if requested. The impact of Alfortish’s prior conviction and disbarment upon the defense attorneys litigating lawsuits that were based upon staged collision has no bearing on any of these issues.

Applying the same law as above, the Court agreed. The Court found that evidence of Alfortish’s disbarment is intrinsic to the charged offenses because it explains why Alfortish did not litigate the staged collision cases and instead gave them to his fiancé and co-conspirator, Vanessa Motta. It is “part and parcel” with the conspiracy.

Specifically, the evidence will support the Government’s position that Alfortish paid slammers to cause car accidents and directed the passengers to Motta and Motta Law for representation because he could not litigate their cases as a disbarred attorney.

The Court found this evidence intrinsic because it is inextricably intertwined with the charged offenses and it “completes the story” of the crime by providing important context regarding Alfortish’s role in the conspiracy, as well as the role of his co-conspirators. It sheds light on the circumstances under which the conspiracy was formed.

Nonetheless, the Court finds that evidence regarding an allegation of Parker’s involvement in a murder that occurred over a decade earlier should be excluded under Federal Rule of Evidence 403. The Court remaind mindful that exclusion of evidence under Rule 403 should occur sparingly, but believes this evidence is appropriate to be excluded under Rule 403.

For the foregoing reasons evidence regarding Sean Alfortish’s 2011 conviction and evidence regarding Parker’s 2010 arrest for a 2005 murder and arson are not admissible at trial as intrinsic evidence while that evidence regarding Alfortish’s disbarment and evidence that Leon Parker physically abused the mother of co-conspirator, Ryan Harris, are admissible at trial as intrinsic evidence.

I am disgusted by people who claim insurance fraud is not a violent crime. It is, and this case makes it clear, that to protect their staged accident scheme the criminal participants in the scheme conspired to a murdered a witness. The intrinsic evidence of the staged accident crime is admissible as it the murder, a crime that is the most violent of all crimes in the penal codes and should be prosecuted separately rather than as part of an insurance fraud case.