Whether a criminal defendant's Sixth Amendment right to present a complete defense is violated when a federal court excludes evidence that a physician's financial transactions were undertaken to comply with state-mandated medical regulatory requirements

Colorado law prohibits non-physicians from owning or controlling medical practices under its Corporate Practice of Medicine (CPOM) doctrine, codified in C.R.S. § 12-240-138. These regulations ensure that medical decision-making remains in the hands of licensed professionals by barring laypersons from exerting financial or operational control over medical corporations. Compliance with CPOM is mandatory for physicians in Colorado, and failure to prevent unauthorized control can result in professional discipline, including revocation of a medical license. Dr. Francis Joseph took steps to remove non-physician Eric Papalini from control of Springs Medical Associates after discovering that Papalini had seized control of the practice ’s finances and placed it in financial jeopardy. His actions — opening a separate business account, securing COVID-19 relief funding, and reasserting financial control —were necessary to comply with CPOM. However, federal prosecutors characterized these state-mandated actions as fraudulent, and the trial court categorically excluded any evidence relating to CPOM compliance, preventing Dr. Joseph from presenting a complete defense. The question presented is: Whether a criminal defendant ’s Sixth Amendment right to present a complete defense is violated when a federal court excludes evidence that a physician ’s financial transactions were undertaken to comply with state-mandated medical regulatory requirements.