US v. Harris, No. 19-10006 (12-29-20)(Bennett, Wallace, & Bea). The 9^th affirms convictions for agg identity theft, 18 USC 1028A, in relation to wire fraud. The defendant ran a speech therapy service.  She used the name and identifications of a speech pathologist to create bills for services that never occurred. Using the name and identifications of the speech pathologist, who had performed other services, were “during and in relation” to the commission of wire fraud. It was not just the conflation or exaggeration of services rendered.  These were fraudulent submissions.

The decision is here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2020/12/29/19-10006.pdf