Monday, February 03, 2020

ID Theft Statute Covers Use of Dead Person's ID


US v. George: George came to the United States from Trinidad & Tobago on a short-term visa and never left. Decades later, while trying to get a government-secured home loan, he used the name, birthdate, and Social Security number of someone else – someone who was already dead. He was charged with false use of a Social Security number and aggravated ID theft and pleaded guilty to both charges. However, he later moved to withdraw the ID theft plea, arguing that the ID theft statute required the use of the ID of a living, not deceased, person. The district court granted the motion and sentenced George to time served on the other count.

The Government appealed and the Fourth Circuit reversed. At issue, the court noted, was whether “person” as used in the statute included persons who were dead. Recognizing that the term was not defined in the act and dictionaries were “inconclusive,” the court retreated to the use of the term in “common parlance” and concluded it included the deceased. That holding, the court pointed out, was the one that every other Circuit to confront the issue had come to. The legislative history also supported that conclusion.

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