Ron Chapman represented Dr. John Patrick Couch in a separate Supreme Court petition. The Supreme Court GVR’d Couch’s case in light of Ruan. The Eleventh Circuit then vacated Couch’s substantive controlled-substance distribution convictions, but left other convictions intact. Couch was not acquitted on all charges and later remained subject to a 20-year sentence.
Major appellate cases often have more than one name behind them. Ruan v. United States became the Supreme Court decision that changed the intent standard for physicians charged under the Controlled Substances Act. Dr. John Patrick Couch, tried alongside Dr. Xiulu Ruan, pursued the same core legal issue through his own petition. Ron Chapman served as Couch’s counsel of record at the Supreme Court.
The prosecution arose from the doctors’ Mobile, Alabama pain practices and included controlled-substance, conspiracy, fraud, kickback, and racketeering allegations. At trial, the jury instructions allowed the government to obtain substantive prescribing convictions without requiring the focused subjective-intent finding later demanded by the Supreme Court.
The appellate strategy was to keep Couch’s case aligned with the constitutional and statutory problem presented in Ruan: what must the government prove about an authorized physician’s state of mind? That distinction is critical. A medical expert can testify that a prescription was outside accepted practice. But after Ruan, that objective opinion alone does not resolve whether the doctor knowingly or intentionally issued an unauthorized prescription.
The Supreme Court held that when a defendant meets the initial burden of producing evidence that the prescribing conduct was authorized, prosecutors must prove beyond a reasonable doubt that the defendant knowingly or intentionally acted in an unauthorized manner. The decision rejected a negligence-like route to conviction for this class of defendants. The full rule and its reasoning appear in the Supreme Court’s Ruan opinion.
Two days after deciding Ruan, the Supreme Court granted Couch’s petition, vacated the judgment, and remanded his case for reconsideration. Ron Chapman’s role as counsel of record and the June 30, 2022 order appear on the Supreme Court docket in Couch v. United States.
Past results do not guarantee or predict a similar outcome. Every case depends upon its individual facts and circumstances.