A federal jury in Alabama convicted Xiulu Ruan and several other pain management physicians of running a medical practice constituting a racketeering enterprise in violation of several federal statutes, including provisions of the Controlled Substances Act. Ruan allegedly prescribed medicines, including Schedule II drugs (many of which are opioids), outside the standard of care for his practice. At trial, prosecutors showed that Ruan and other physicians in his practice prescribed medications for their own financial gain rather than for the benefit of their patients. Ruan and other defendants challenged their convictions, and the U.S. Court of Appeals for the Eleventh Circuit affirmed.
The case was decided on June 27, 2022. The Court held that : Section 841’s “knowingly or intentionally” mens rea applies to the statute’s “except as authorized” clause. Once a defendant meets the burden of producing evidence that his or her conduct was “authorized,” the Government must prove beyond a reasonable doubt that the defendant knowingly or intentionally acted in an unauthorized manner. Justice Breyer delivered the opinion of the Court, in which Chief Justice Roberts and Justices Sotomayor, Kagan, Gorsuch, and Kavanaugh joined. Justice Alito filed an opinion concurring in the judgment, in which Justice Thomas joined, and in which Justice Barrett joined as to Parts 1–A, 1–B, and 2.
Credit: Oyez, LII Supreme Court Resources, Justia Supreme Court Center, available at: https://www.oyez.org/cases/2021/20-1410