Hickman v. State

Summary

The Supreme Court of Delaware affirmed Hickman’s forgery convictions, holding that charging one forgery count for each altered document did not violate the Double Jeopardy Clause’s multiplicity doctrine. Because the forgery statute criminalizes possession of a written instrument and each altered bank statement or tax return was a separate instrument conveying distinct misinformation, the State properly charged multiple offenses. The issue was reviewed for plain error because Hickman had not raised it below.