Steven Aaron is a Partner in Rimon’s litigation practice. A leading white collar and government investigations defense lawyer with over 28 years of experience, Mr. Aaron has tried more than 45 civil and criminal jury trials in state and federal courts, defending clients in criminal prosecutions, government investigations and enforcement actions, as well as representing clients as both plaintiffs and defendants in general and complex commercial litigation.
Mr. Aaron is one of a very select few lawyers honored by BTI Consulting as a ‘‘Client Service All-Star,’’ based solely on interviews with more than 300 corporate counsel and leading legal decision-makers. This ranking illustrates his commitment and dedication to strategically solving problems for his clients.
Mr. Aaron’s practice covers a widely diverse subject matter including litigation under the Foreign Corrupt Practices Act (FCPA), the False Claims Act (FCA), the Real Estate Settlement Procedures Act (RESPA) and the Occupational Safety and Health Act (OSHA). His practice is also focused on consumer issues and unfair trade practices, including the Telephone Consumer Protection Act (TCPA), mortgage fraud and business torts.
Mr Aaron has represented both individuals and companies across a wide range of industries including health care, financial services, construction and retail, in criminal and regulatory investigations and proceedings conducted by federal agencies and/or their state and local counterparts. These agencies include the following:
- Office of Inspector General (OIG), US Department of Health and Human Services
- US Drug Enforcement Administration (DEA)
- US Department of Justice (DOJ)
- US Federal Bureau of Investigation (FBI)
- US Federal Election Commission (FEC)
- US Federal Trade Commission (FTC)
- US Internal Revenue Service (IRS)
- US Securities and Exchange Commission (SEC)
Healthcare Defense and Compliance
- Representation of a global health care/medical device company in connection with parallel investigations by the SEC and the DOJ into alleged violations of the FCPA in multiple countries around the world. Helped the company resolve the inquiry through a non-prosecution agreement and settled enforcement action with the SEC and the DOJ.
- Representation of a US$72 billion retail drug store chain in an investigation by the Missouri Attorney General’s office for alleged deceptive trade practices relating to the advertising, marketing and sale of merchandise. The AG claimed that the client’s pricing system was deceptive and confusing, resulting in significant overcharges to consumers. After moving to dismiss the case based on improper investigative techniques, the matter was resolved by a consent judgment that focused on price monitoring and related compliance initiatives, with no fine or payment made by the client.
- Representation of a regional hospice system while responding to a criminal and civil investigation by the US DOJ, the US Attorney for the Western District of Missouri, the OIG and the FBI for alleged violations of the False Claims Act in the submission of claims for Medicare reimbursement. The federal government declined to file any criminal charges and the civil matter was subsequently resolved through a mutually-agreed-upon monetary settlement with no exclusion or debarment.
- Conducting an internal investigation into allegations of ‘‘kick back’’ payments for referrals from a Florida community hospital to home health agencies and adult living facilities.
- Representation of a pharmacy and its pharmacist in a criminal investigation by the DEA and the DOJ into allegations that the pharmacist violated federal laws regarding the delivery of certain controlled substances. After months of negotiating with the DOJ, we were able to convince the government to take away felony charges and to proceed with a misdemeanor charge against the entity only, with a fine amount agreed to by the parties.
- Serving as counsel for a physician radiologist in connection with criminal and civil investigations by the DOJ, the OIG and the FBI of numerous physicians, as well as large public health system, for alleged violations of the False Claims Act.
- Defending an investigation by the Kansas Board of Emergency Medical Services seeking termination of the client’s license for violations of state regulations, including allegations of self-medication from a helicopter medicine cabinet while on duty. Client was placed on probation while maintaining an active license.
- Representation of a high-level employee in one of the nation’s leading research institutes who was subpoenaed to testify before a grand jury investigation into weapons of mass destruction.
- Defending a US-based payday lender and its affiliates against a class action complaint filed under the TCPA on behalf of a certified class of about 100,000 cell phone users. Successfully moved for summary judgment on all claims, avoiding potential statutory damages of between US$50 million and US$150 million.
- Obtaining four complete defense verdicts on behalf of a nationwide mortgage lender (more than US$1 billion in closed loan volume) in civil jury trials alleging mortgage fraud, violations of RESPA and conspiracy with a mortgage broker and others to inflate appraisals to defraud homeowners in mortgage transactions.
- Defending a commercial and residential home building company and its president in responding to a criminal investigation by the DOJ and the FBI involving claims of mortgage fraud and conspiracy relating to several hundred homes built and sold by the company.
- Defending a US-based payday lender and its related companies in an FTC investigation into multiple alleged violations of federal law with respect to its loan origination and debt collection processes. The government closed the investigation with no charges filed or monetary payments made by clients.
- Responding to FEC allegations that a high-net-worth individual made a political contribution exceeding US$1 million through, and in the name of, another individual.
- Defending a US$44 billion supply chain services company charged by the Kansas Department of Revenue’s Taxation Division with failure to provide indicia of tax payment with respect to cigarette cartons sold to a retailer, including tax stamps mutilated by improper stamping technique at client’s plant. After negotiations that included the client’s agreement to revamp policies and procedures and implement a compliance plan, our client obtained a complete dismissal of charges with only a minor fine assessed.
- Counseling a high-net-worth individual and his multiple companies in connection with an IRS Global Financial Crimes Unit investigation arising after the IRS declined to allow the client into the IRS Offshore Voluntary Disclosure Initiative.
- Acting as counsel for one of the largest secondary metal recycling companies in the Midwest and its owners in a multi-jurisdictional criminal investigation by the IRS and the FBI, among others, for alleged violations of various state and federal laws and defended the company in a civil lawsuit arising from the investigation.
Other Notable Cases
- Obtaining a complete defense civil jury verdict on behalf of a gasoline and convenience store retailer with US$10 billion in sales that was sued for malicious prosecution and false imprisonment as a result of criminal activity at one of its 660-plus stores in the United States.
- Obtaining a complete defense civil jury verdict on behalf of a supermarket chain with US$7.6 billion in sales that was sued for malicious prosecution and false imprisonment as a result of criminal activity at one of its 235-plus stores in the United States.
- Conducting an internal investigation into a shooting death on a university campus. The decedent was allegedly involved in a carjacking when confronted by University police. An altercation ensued which resulted in the use of deadly force to subdue the suspect. Our work for the university included assisting the local police department with its investigation into the conduct of university police, and its submission of evidence to a grand jury. The investigation also looked at potential civil liability of the university and whether university police policies and procedures were adequate to ensure student safety.
- Defending a university’s head football coach after his suspension from the National Collegiate Athletic Association (NCAA) for rule violations. The coach, who was suspended for one game as punishment for academic irregularities, was not represented in the underlying NCAA investigation. Work included interviewing football staff and academic counselors to determine whether violations occurred, the reasons for the coach’s actions, and whether an appeal of the suspension was warranted. After discussions with the NCAA, the suspension was reversed.
- Defending a minority-owned and -operated general contractor with operations in the US and Africa (Ethiopia, South Sudan and Djibouti) against charges brought by the US government for failure to pay the prevailing wage. After repeated negotiations with the government on a variety of issues, including remedial actions taken by the contractor, the government agreed to a deferred prosecution agreement, dismissed all charges and the client was not debarred.
- Representation of a certified steel erector company that specialized in the installation of structural steel, joists and girders in responding to federal criminal charges resulting from the death of an iron worker, allegedly due to OSHA violations.
AWARDS & RECOGNITION
- Recognized in the ‘‘Criminal Defense: White Collar’’ category, The Best Lawyers In America, 2011-2021
- Recognized as a ‘‘Client Service All-Star,’’ BTI Consulting Group, 2017
- Selected ‘‘Best of the Bar,’’ Kansas City Business Journal, 2017
- Ranked ‘‘Best of the Bar in Litigation,’’ Kansas City Business Journal, 2013-2015
- Martindale-Hubbell: Rated AV Preeminent (the highest level)
- American Bar Association
- Kansas City Metropolitan Bar Association
- Maricopa County (Arizona) Bar Association
- Steve Palermo Endowment for Spinal Cord Injury Research
News, Events, & Insights
- Rimon Law welcomes Steven M. Aaron as Litigation Partner in its Kansas City office
News January 6, 2021