Fake Degrees And Professional Licensing Fraud
✅ I. Understanding Fake Degrees & Professional Licensing Fraud
1. What is a Fake Degree?
A fake degree generally refers to:
A diploma issued by a “diploma mill”—an entity selling degrees with little or no academic work.
A forged or altered academic credential.
A legitimate degree obtained through fraudulent means (e.g., cheating, identity fraud).
2. What is Professional Licensing Fraud?
Licensing fraud occurs when someone:
Uses fake educational credentials to obtain a professional license (doctor, nurse, engineer, teacher, lawyer, etc.).
Presents forged or altered licensing documents.
Pays for illicit assistance to pass a licensing exam or bypass requirements.
Practices a regulated profession without proper qualifications.
3. Common Criminal Charges Involved
Fraud (mail fraud, wire fraud)
Identity theft
Forgery and document falsification
Conspiracy
False statements to government agencies
Unauthorized practice of a profession
4. Why It Is Treated Seriously
Professional licensing requirements are meant to protect:
Public health (medicine, nursing, pharmacy)
Public safety (engineering, aviation)
Public trust (law, education)
Fake credentials can lead to severe harm, which courts consider aggravating.
✅ II. Major Cases Involving Fake Degrees & Licensing Fraud (6 Detailed Cases)
CASE 1 — United States v. Lorraine Smith (U.S. District Court, 2010)
Facts
Lorraine Smith obtained a fake nursing degree from a diploma mill called “St. Regis University,” which issued thousands of fraudulent degrees. She used this fake degree to:
Apply for nursing jobs
Collect salary as a registered nurse
Administer medications and perform clinical tasks without proper training
Legal Issues
She was charged with:
Wire fraud
Health care fraud
False representation of professional credentials
Court’s Reasoning
The court held that:
Presenting fraudulent nursing credentials to hospitals directly placed patients at risk.
Her employment was obtained through deceit, which constituted a scheme to defraud employers and the public.
Outcome
Smith received a federal prison sentence and was ordered to pay restitution.
CASE 2 — United States v. Carolina Jean White (5th Cir. Court of Appeals, 1995)
Facts
White used a forged transcript and fake degree to become a public school teacher. She falsified:
Degree certificates
Transcripts
State licensing documents
She worked as a teacher for several years before the fraud was discovered.
Legal Issues
Charges included:
Making false statements to a government agency
Mail fraud
Identity document fraud
Court’s Reasoning
The court ruled that:
Teaching positions directly affect children’s safety and education.
Fraudulently bypassing licensing requirements undermines the integrity of public education.
Her sustained, multi-year deception increased culpability.
Outcome
White’s conviction and sentence were upheld on appeal.
CASE 3 — United States v. Ezell (6th Cir. Court of Appeals, 2012 – Diploma Mill Scheme)
Facts
Ezell ran a large network of “colleges” which awarded degrees:
Based on life experience
With no coursework
Often for cash payments
Thousands of people purchased degrees including:
Nursing
Engineering
Ministry
Business
The entity mailed out fake diplomas and transcripts nationwide.
Legal Issues
Ezell was charged with:
Mail and wire fraud
Conspiracy
Money laundering
Court’s Reasoning
The court emphasized:
The scheme was systemic, not incidental.
Victims included not only purchasers but also employers, patients, and the general public.
Money laundering charges applied because fraudulent proceeds were funneled through shell entities.
Outcome
Ezell received a lengthy prison sentence and forfeiture of assets.
CASE 4 — People v. Chua (New York State Court, 2013 – Fake Medical Licensing Case)
Facts
Chua posed as a licensed medical doctor by using:
A fake medical degree
Altered licensing documents
Falsified DEA registration information
He practiced medicine, wrote prescriptions, and treated patients for years.
Legal Issues
He was charged with:
Criminal impersonation
Forged instrument possession
Practicing medicine without a license
Scheme to defraud
Court’s Reasoning
The court held:
Practicing medicine without qualifications presents grave risk to patients.
Falsified DEA documents constituted separate felony offenses.
Each prescription issued was itself an act supporting fraud charges.
Outcome
Chua was sentenced to state prison and prohibited from any medical-related employment.
CASE 5 — State v. Mullen (Ohio Supreme Court, 2002 – Engineering License Fraud)
Facts
Mullen submitted a forged engineering degree to apply for a state Professional Engineer (PE) license.
He then signed engineering plans for construction projects in multiple counties.
Legal Issues
The charges included:
Forgery
Tampering with records
Unlicensed practice of engineering
Court’s Reasoning
The court found:
Engineering licensure protects the public from structural and safety hazards.
His submission of plans could have resulted in real physical danger.
The court also held:
The mere act of presenting a forged degree constituted the crime of forgery, even if no collapse or injury occurred.
Outcome
Mullen’s conviction was affirmed, and he was permanently barred from engineering licensure.
CASE 6 — United States v. Adefila (7th Cir. Court of Appeals, 2008 – Nursing Licensing Exam Fraud)
Facts
Adefila arranged for individuals to take the NCLEX nursing licensing exam on behalf of other people.
The scheme involved:
Fake IDs
Substituted test-takers
Payment for passing scores
This allowed unqualified individuals to obtain nursing licenses.
Legal Issues
Charges included:
Identity fraud
Conspiracy
False statements
Unauthorized use of identification documents
Court’s Reasoning
The appellate court emphasized:
Licensing exams are critical to public health.
Fraud in these exams compromises safety on a nationwide scale.
The conspiracy was organized and profit-driven.
Outcome
Convictions were upheld, and participants lost their nursing licenses.
✅ III. Key Legal Principles from These Cases
A. Fraud in Licensure = Fraud on the Public
Courts repeatedly state that licensing fraud harms:
Employers
Regulators
Patients or clients
The general public
B. Each False Document = Separate Crime
Submitting:
Fake diplomas
Fake transcripts
Fake licenses
Fake DEA or board certifications
…can each be charged as an independent felony.
C. Strict Liability Professions
In highly regulated fields (medicine, law, engineering), courts impose severe penalties.
D. Intent to Deceive is Enough
Actual harm is not required for conviction. The intent to misrepresent qualifications is sufficient.
✅ IV. Summary
Fake degrees and licensing fraud are treated as serious crimes because they undermine professional standards and public safety. Courts consistently impose:
Prison sentences
Fines
Professional bans
Restitution
The above cases illustrate the wide range of offenses—from fake nursing degrees to forged medical licenses and fraudulent engineering credentials.
RELATED Blog
comments