The U.S. Court of Appeals for the Second Circuit affirmed a district court judgment against Dr. Colin Clarke and his medical practice in their dispute with multiple GEICO insurance entities, according to a summary order issued January 5, 2026.
The case, styled *Clarke v. GEICO* (2d Cir. 2026), involved Colin Clarke and Colin Clarke, M.D., P.C. as plaintiffs-appellants against Government Employees Insurance Company, GEICO Indemnity Company, GEICO General Insurance Company, and GEICO Casualty Company as defendants-appellees.
A three-judge panel consisting of Circuit Judges Steven J. Menashi, Beth Robinson, and Myrna Pérez heard the appeal at the Thurgood Marshall United States Courthouse in New York City. The court issued its decision as a summary order, which under federal appellate rules does not carry precedential effect but may be cited in future proceedings.
The underlying dispute appears to have originated from civil RICO actions that GEICO brought against the medical practice, though the complete details of the original claims were not fully disclosed in the available summary order text. The case was initially heard in the U.S. District Court for the Eastern District of New York under Judge Block.
Dr. Clarke and his medical practice were represented by Wesley R. Mead of Mead Law Firm, P.C. in Milford, Connecticut, with assistance from John G. Balestriere of Balestriere in New York. The GEICO entities retained Evan H. Krinick and a team of attorneys from Rivkin Radler LLP in Uniondale, New York, including Barry I. Levy, Cheryl F. Korman, Steven T. Henesy, and Merril S. Biscone.
The Second Circuit's summary order was notably brief, simply stating that "upon due consideration, it is hereby ORDERED, ADJUDGED, and DECREED that the judgment of the district court is AFFIRMED." This type of abbreviated ruling is common in summary orders when appellate courts find no reversible error in the lower court's decision.
The case represents another instance of disputes between medical providers and insurance companies, a relationship that has been the subject of increasing legal scrutiny in recent years. Such disputes often involve questions about billing practices, coverage determinations, and compliance with various federal and state regulations governing insurance and healthcare.
The involvement of RICO allegations suggests the original dispute may have concerned allegations of fraudulent or deceptive practices, as the Racketeer Influenced and Corrupt Organizations Act is commonly used in civil litigation involving patterns of alleged wrongdoing. RICO claims allow for enhanced damages and attorney fees in successful cases, making them powerful litigation tools for both plaintiffs and defendants.
Summary orders like the one issued in *Clarke v. GEICO* are designed to resolve appeals efficiently when the legal issues are straightforward or when the appellate court determines that the lower court's analysis was correct. While such orders may be cited, they do not establish binding precedent for future cases, unlike published opinions that receive full appellate court treatment.
The Eastern District of New York, where the case was originally heard, frequently handles complex commercial litigation involving insurance disputes. The district has developed considerable expertise in such matters given New York's status as a major insurance and financial center.
For Dr. Clarke and his medical practice, the Second Circuit's affirmance represents the conclusion of their federal court challenge. The summary order provides no indication of damages, injunctive relief, or other remedies that may have been awarded in the underlying district court proceeding.
The case also highlights the ongoing tensions in the healthcare industry regarding insurance reimbursement and billing practices. Medical providers and insurance companies regularly clash over payment amounts, coverage decisions, and compliance with various regulatory requirements.
The Second Circuit's handling of the case through summary order suggests the appellate issues were not legally complex or that the district court's reasoning was clearly correct under existing law. Such dispositions help federal appeals courts manage heavy caseloads while ensuring that meritorious appeals receive appropriate consideration.
The affirmance means that whatever judgment the Eastern District of New York entered against Dr. Clarke and his medical practice will stand. The summary order's brevity prevents detailed analysis of the specific legal theories or factual findings that supported the district court's decision.
This case serves as a reminder of the complex legal landscape surrounding healthcare provider-insurance company relationships and the potential consequences when such disputes escalate to federal litigation involving claims under statutes like RICO.