N.Y. Laws » CHAPTER Penal / PART Specific Offenses / TITLE Offenses Involving Fraud / ARTICLE Insurance Fraud
New York Consolidated Laws

N.Y. Penal Law § 176.15 (2026)

Insurance fraud in the fourth degree

✓ current as of May 2026
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§ 176.15 Insurance fraud in the fourth degree.
  A person is guilty of insurance fraud in the fourth degree when he
commits a fraudulent insurance act and thereby wrongfully takes, obtains
or withholds, or attempts to wrongfully take, obtain or withhold
property with a value in excess of one thousand dollars.
  Insurance fraud in the fourth degree is a class E felony.
Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1985–2025 · leading case: Matter of Graham v. Coughlin, 531 N.E.2d 640 (NY 1988).
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Matter of Graham v. Coughlin, 531 N.E.2d 640 (NY 1988). · cites it 4× “Petitioner's contention is that he did not have any fraudulent intent but, instead, merely "provide[d his friend] with means or opportunity" to commit mail fraud, the equivalent of committing only criminal facilitation in the fourth degree, a class A misdemeanor (Penal Law § 115.”
Brown Ex Rel. Rhiner v. Kerkhoff, 504 F. Supp. 2d 464 (S.D. Iowa 2007). “” N.Y. Penal Law § 176.15 . A violation of New York Penal Law section 176.”
Howard v. Stature Elec., Inc., 986 N.E.2d 911 (NY 2013). “Ultimately, claimant entered a plea of guilty to only one charge, insurance fraud in the fourth degree (Penal Law § 176.15), in satisfaction of all charges.”
People v. Alfaro, 108 A.D.2d 517 (N.Y. App. Div. 1985). “surance fraud involving pecuniary values in excess of $1,500 as Class D felonies, track the classifications for larcenies and will be an indication by the Legislature that the State will no longer tolerate crime in the insurance field” (Governor’s approval memorandum, 1981 NY…”
People v. Waldriff, 46 A.D.3d 1448 (N.Y. App. Div. 2007). “Memorandum: On appeal from a judgment convicting him upon a jury verdict of insurance fraud in the fourth degree (Penal Law § 176.15) and attempted grand larceny in the fourth degree (§§ 110.”
In re Hochberg, 259 A.D.2d 94 (N.Y. App. Div. 1999). “Fourth-degree insurance fraud, the lowest degree that is still a felony, similarly requires that the money at issue be in excess of $1,000 (Penal Law § 176.15). The definition of scheme to defraud in the first degree, to the extent that it is applicable to these facts, similarly…”
People v. Aksoy, 644 N.E.2d 1362 (NY 1994). “Indeed, that higher degrees of the crime of insurance fraud are correlated with a specific value of property wrongfully secured indicates a legislative intent to equate the criminal act with the filing of the entire claim and not with the filing of each individual statement…”
People v. Hade, 255 A.D.2d 768 (N.Y. App. Div. 1998). “We further find no error in the denial of his request for a charge on the lesser included offense of insurance fraud in the fourth and fifth degrees and petit larceny (see, Penal Law §§ 176.15, 176.10, 155.25). A lesser included offense charge must be grounded upon a two-pronged…”
People v. O'Boyle, 136 Misc. 2d 1010 (N.Y. Sup. Ct. 1987). “(Penal Law § 176.15; see also, Hechtman, Practice Commentary, McKinney’s Cons Laws of NY, Book 39, Penal Law § 176.”
People v. Cordell, 2020 NY Slip Op 06606 (N.Y. App. Div. 2020). “Memorandum: On appeal from a judgment convicting him upon a jury verdict of insurance fraud in the fourth degree (Penal Law § 176.15) and falsifying business records in the first degree (§ 175.”
People v. Trump, 2025 NY Slip Op 04756 (N.Y. App. Div. 2025). · cites it 4× “Footnote 56: Penal Law § 176.15 (the fourth degree), a class E Felony, applies to a fraudulent insurance act for "value in excess of one thousand dollars.”
People v. Wong, 2017 NY Slip Op 4997 (N.Y. App. Div. 2017). “Memorandum: Defendant appeals from a judgment convicting him upon his plea of guilty of insurance fraud in the fourth degree (Penal Law § 176.15) and criminal possession of a forged instrument in the second degree (§ 170.”
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