A jury convicted Roger Bergman of conspiracy to commit health-care and wire fraud and conspiracy to make false statements relating to health-care matters, while Rodolfo Santaya was convicted of health-care fraud and kickback conspiracies and receiving kickbacks. Bergman argued that his departure from American Therapeutic Corporation established withdrawal from the conspiracy before the statute of limitations expired; both defendants also challenged the sufficiency of the evidence and trial rulings. The Eleventh Circuit held that the evidence permitted the jury to reject Bergman’s withdrawal defense because merely ending participation is not enough, and an effective withdrawal requires affirmative steps inconsistent with the conspiracy that are communicated to co-conspirators or law enforcement. It also held that sufficient evidence supported Santaya’s convictions and found no reversible error in jury selection, cross-examination, or the admission of Medicare-coverage testimony. The court affirmed both defendants’ convictions and sentences. Judge Martin dissented, concluding that Bergman satisfied the circuit’s withdrawal test as a matter of law and that the majority improperly added a voluntariness requirement.