Published on October 7, 2025 by Morgan Black  
Dike Minor Chinelo

Chinelo Diké-Minor, associate professor of law at Samford University’s Cumberland School of Law, has been cited in a published opinion by the United States Court of Appeals for the Ninth Circuit, marking a significant recognition of her scholarly impact on federal jurisprudence.

In United States v. Schena, No. 23-2989, the Ninth Circuit issued the first appellate court interpretation of the Eliminating Kickbacks in Recovery Act (EKRA). The court affirmed the conviction of a laboratory operator who paid marketing intermediaries to induce medically unnecessary referrals for allergy and COVID-19 testing. In its analysis, the court referenced Diké-Minor’s research on EKRA and the broader landscape of anti-kickback laws, underscoring the relevance of her scholarship to contemporary legal challenges in health care fraud enforcement.

Diké-Minor, a former Assistant U.S. Attorney and nationally recognized expert in health care fraud, has published extensively on the gaps in federal anti-kickback statutes. Her work, including “The Untold Story of the United States’ Anti-Kickback Laws” published in the Rutgers Journal of Law & Public Policy and “The Devil Made Me Do It: An Argument for Expanding the Anti-Kickback Statute to Cover Private Payers” published in the Connecticut Law Review, has been influential in shaping policy discussions and legal interpretations around health care fraud prevention.

This citation by the Ninth Circuit not only highlights the practical importance of Diké-Minor’s scholarship but also reflects Cumberland School of Law’s commitment to producing legal research that informs and influences the highest levels of judicial decision-making.