Workers' compensation fraud

1. Whether the Federal Employees’ Compensation Act (FECA), a federal workers’ compensation statute rather than a health insurance statute, qualifies as a “plan” or “contract” as those undefined operative terms appear in the definition of “health care benefit program” in 18 U.S.C. § 24(b). 2. Whether this Court should disapprove United States v. Anderson, 980 F.3d 423, 428 (5th Cir. 2020), which the Fifth Circuit panel applied by rote in petitioner’s case by uncritically giving “a broad meaning” to “health care benefit program” in 18 U.S.C. § 24(b)—without even mentioning the undefined key terms “plan” or “contract.”? 3. Whether this Court should grant certiorari to clarify the proper application of the rule of lenity to ambiguous criminal statutes in view of the conflicting approaches in this Court’s precedent. Compare, e.g., Wooden, 595 U.S. 360, 376-78 (2022) (Kavanaugh, J., concurring) (arguing in favor of a narrow approach to the rule of lenity and contending that “the rule of lenity has appropriately played only a very limited role in this Court’s criminal case law”), with id. at 388-97 (Gorsuch, J., concurring, joined by Sotomayor, J.) (arguing in favor of a broad approach to the rule of lenity and noting its application dating from the early decades of this country’s history).