State v. Valdiviezo-Martinez

Summary

The court affirmed Valdiviezo-Martinez's identity-theft conviction, holding that using another person's Social Security number to obtain and maintain employment can constitute fraud even when the defendant performed the work and received wages legitimately earned. It also held that the charged conduct was sufficiently shown to have occurred on or about the charged date because the statutory use and deception continued through the employment relationship, and that the statute was not unconstitutionally vague. The court declined to resolve broader questions about preservation of statute-of-limitations defenses and whether the unit of prosecution could support separate offenses.