United States v. Alexander, No. 12-30156 (9th Cir. 2013)
Annotate this CaseDefendant appealed his conviction for aggravated identity theft. At issue on appeal was whether a counterfeit paper check that bears a victim's true name, bank account number, and routing number was a "means of identification of another person" for the purposes of the aggravated identity theft statute, 18 U.S.C. 1028A, 1028(d)(7). The court concluded that, under the plain statutory language of the aggravated identity theft statute, the names and banking numbers on defendant's counterfeit check were a "means of identification." Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal Law. Affirming a conviction for aggravated identity theft, the panel held that a victim’s true name and banking numbers appearing on a counterfeit check are a “means of identification” for purposes of 18 U.S.C. §§ 1028A, 1028(d)(7).
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