Barry Zalma, Inc.

09/04/2026

Qui Tam Relators are not officers of the United States

Attempt to use Constitution to Stop a Qui Tam False Claims Act Case Post 5486 FCA’s Qui Tam Provisions do not Violate the Appointments Clause. In United States Of America, Clarissa Zafirov, ex rel; Dr. v. Florida Medical Associates, LLC, d.b.a. Vipcare, Physician Partners, LLC, Anion Technologies, LLC, Freedom Health, Inc., Optimum Healthcare, Inc., Physician Partners Specialty Services, LLC, et al....

Attempt to use Constitution to Stop a Qui Tam False Claims Act Case Post 5486 FCA’s Qui Tam Provisions do not Violate the Appointments Clause. In United States Of America, Clarissa Zafirov, ex rel;…

09/03/2026

Res Judicata Produces Certainty

You Only Get One Chance to Sue Litigation is a Win or Lose Proposition. Post 5484 In David Cromp v. Johnny Harkrider, Monique Harkrider, and their Marital Community, dba Able Plumbing Plus, No. 61678-5-II, Court of Appeals of Washington, Division 2 (August 25, 2026) David Cromp hired Able Plumbing Plus in 2018 to install plumbing, including two toilets, at his residence....

You Only Get One Chance to Sue Litigation is a Win or Lose Proposition. Post 5484 In David Cromp v. Johnny Harkrider, Monique Harkrider, and their Marital Community, dba Able Plumbing Plus, No. 616…

09/02/2026

A Charge of Insurance Fraud is not Grounds for Deportation

Habeas Corpus Petition Granted Post 5483 Over Staying Visa & Charge of Insurance Fraud Still Entitled to Habeas Relief and a Bond Hearing In Hernan Guillermo Palomino-Crespo v. Warden, Glades County Detention Center et al., No. 2:26-cv-02322-SPC-NPM, United States District Court, M.D. Florida, Fort Myers Division (August 26, 2026) Hernan Guillermo Palomino-Crespo's Amended Petition for Writ of Habeas Corpus, the government's response and Palomino-Crespo's reply....

Habeas Corpus Petition Granted Post 5483 Over Staying Visa & Charge of Insurance Fraud Still Entitled to Habeas Relief and a Bond Hearing In Hernan Guillermo Palomino-Crespo v. Warden, Glades …

09/01/2026

Zalma’s Insurance Fraud Letter –September 1, 2026

ZIFL Volume 30, Issue 17 Subscribe to ZIFL Here THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th year of publication dedicated to those involved in educing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at…...

ZIFL Volume 30, Issue 17 Subscribe to ZIFL Here THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th year of publication dedicated to those invol…

08/31/2026

Convicted Felon Obtained Weapons by Fraud

Fraud & Murder Post 5438 Not Every Evidentiary Error, However, Leads to a New Trial. In United States of America v. Darius Carter, No. 24-3418, United States Court of Appeals, Eighth Circuit (August 25, 2026) Darius Carter, a convicted felon, could not lawfully buy a fi***rm. His girlfriend, Sarah Mason, was also unable to purchase one because she was only 20 years old....

Fraud & Murder Post 5438 Not Every Evidentiary Error, However, Leads to a New Trial. In United States of America v. Darius Carter, No. 24-3418, United States Court of Appeals, Eighth Circuit (A…

08/28/2026

A Factual Dispute is Enough to Require Trial

No Summary Judgment for Bad Faith for Lack of Evidence Post 5437 Genuine Dispute of Material Fact Avoids Summary Judgment In Riley and Rebecca Ross v. Allstate Vehicle And Property Insurance Company, and Illinois Corporation, No. 2:25-CV-00006-JAG, United States District Court, E.D. Washington (August 18, 2026), Pending before the USDC was Defendant's Motion for Partial Summary Judgment the plaintiffs brought claims against Allstate arising from its handling of an insurance claim....

No Summary Judgment for Bad Faith for Lack of Evidence Post 5437 Genuine Dispute of Material Fact Avoids Summary Judgment In Riley and Rebecca Ross v. Allstate Vehicle And Property Insurance Compan…

08/27/2026

The Need to Read an Insurance Policy

Courts Have Established a Duty to Read an Insurance Policy Post 5436 Subscribe to my substack at You will read from this link until you reach the the end of this blog post as the free part of Excellence in Claims Handling. You should consider joining as a paid member to get full access to articles for members only, to our news, analysis, insurance coverage, claims, insurance fraud and insurance webinars, by clicking at the button above....

Courts Have Established a Duty to Read an Insurance Policy Post 5436 Subscribe to my substack at You will read from this link until you reach the the end of this blog post as the free part of Excel…

08/26/2026

Insurance Proceeds Available in Specific Enforcement Action

Trial Court Must Determine What Part of the Insurance Proceeds Plaintiff was Entitled to Receive Post 5435 Specific Performance is an Equitable Remedy In Landon Cole v. Coty Link, No. 2024AP1372, Court of Appeals of Wisconsin, District III (August 18, 2026) Cole and Link entered into a purchase agreement for real property at 102 Knapp Street in Chetek, Wisconsin, for $105,000....

Trial Court Must Determine What Part of the Insurance Proceeds Plaintiff was Entitled to Receive Post 5435 Specific Performance is an Equitable Remedy In Landon Cole v. Coty Link, No. 2024AP1372, C…

08/26/2026

Offer Made and Accepted Creates Enforceable Contract

Policy Limits Demand Accepted Settles Claim Post 5434 See the full video at and at A Contingent Offer Accepted Ends the Dispute In Farmers Insurance Exchange, a California Reciprocal Insurance Exchange, The Superior Court For The County Of San Bernardino, Kathleen Ann Wood, E087128, California Court of Appeals, (July 9, 2026) Farmers Insurance Exchange insured Doyle Archer under an automobile policy with bodily injury limits of $15,000 per person and $30,000 per accident....

Policy Limits Demand Accepted Settles Claim Post 5434 See the full video at and at A Contingent Offer Accepted Ends the Dispute In Farmers Insurance Exchange, a California Reciprocal Insurance Exch…

08/25/2026

Just Being Wrong is not Bad Faith

Mere Negligence, Poor Judgment, Delay, Inadequate Investigation, Valuation Disagreement, or an Honest Mistake May Not Establish Bad Faith. Post 5433 In Joseph Russell Falasco v. USAA Casualty Insurance Company, No. 25-2632, United States Court of Appeals, Eighth Circuit (August 18, 2026) Joseph Russell Falasco insured a restored 1974 Porsche 911S through USAA. After the Porsche caught fire in August 2023, Falasco reported the loss and initially believed the vehicle was a total loss....